Key Benefits
- Learn how to assess the sanctions risk exposures of equity, credit and currency cash and derivative products as separately defined by US vs EU/UK regulators
- Learn what specifically constitutes financing, investment, facilitation or brokering of transactions under the relevant sanctions regimes, as well as specific prohibitions in respect of financial services and capital markets
- Build skills in handling complex ownership, beneficial ownership, and due diligence issues linked to sanctioned individuals, their proxies, associates and high risk entities
Do You Need to Attend This Course?
The course is suitable for staff in:
Banks, asset managers, hedge funds, brokers and other financial institutions, including:
Compliance, Audit, Legal and other Risk Professionals
Frontline Relationship Managers, Advisers, Salespersons and Traders who make routine decisions on financing and investments on behalf of their customers and firms
Customer Due Diligence, Transaction Processing, Operations and Administrators
International Law Firms, Accountants, Real Estate Agents, Trust & Corporate Services
Commodity Trading Firms
Exchanges, Multilateral Trading Facilities and Depositories
Oil companies and multinationals
Technical Content
Session 1: Ownership & Customer Due Diligence
The challenge of determining ownership structures given the propensity for sanctioned individuals and entities to use family members and other proxies.
The Ownership Challenge
OFAC 50% Rule
OFAC 33% Rule
Enhanced Due Diligence on Beneficial Ownership
Strategic Dilemma: Risk Appetite
Exercise: Hidden Ownership
Session 2: US Sanctions on Russia I
Countering American Adversaries Through Sanctions Act (CAATSA)
Russian Sectoral Sanctions Identifications (SSIs) Directives 1, 2, 3 & 4
CAATSA Definitions of Debt & Equity
Application of Secondary Sanctions
Facilitation & State Entities
CAATSA Definition of Investment
General Licence 1B: Derivatives
CAATSA Anti-Avoidance & Facilitation Provisions
Case Study: Company A
Case Study: The Russian Laundromat
Case Study: Russian Offshore Financing
Case Study: Sibneft Privatisation
Exercise: Product Evaluation
Session 3: US Sanctions on Russia II
Executive Order 14024
Russian Harmful Foreign Activities Directive 1 Government & Major Sectors of the Russian Economy
Financing, Facilitating or Supporting
Deceptive & Structured Transactions: Digital & Physical Assets
Secondary Sanctions: Foreign Financial Institutions
Russian Bank Units and Subs Overseas
Russian Harmful Foreign Activities Directive 2
Prohibitions on Correspondent & Payable Through Accounts
Russian Harmful Foreign Activities Directive 3
New Debt & Equity Restrictions Major Russian Entities
Russian Harmful Foreign Activities Directive 4
Restrictions on Russian Sovereign Debt
Prohibitions on Occupied Ukraine
Prohibitions of Executive Orders 14066, 14068, 14071
Energy, Investments, Luxury Goods and Services
Facilitation, Oligarchs & Proxies
Other Major Sanctions
Case Study: Putin & the Proxies
Exercise: GVA Capital
Session 4: EU Sanctions on Russia
Russia Sanctions Overview
EU Sectoral Sanctions Major Industry
Financial Sector
Capital Markets & Financing
Investment Services
EU Definitions
Financing
Investment Services
Transferable Securities
Derivatives
EU Treatment of Derivatives
Prohibitions
Trust & Corporate Services
Brokering & Financing
Circumvention
Annexed Territories
Professional Services
Case Study: OFAC Settlement Wells Fargo
Case Study: Mirror Trades
Session 5: UK Sanctions on Russia
The Russia (Sanctions) (EU Exit) Regulations 2019 Transferable Securities
Derivatives
Loans & Credit
Occupied Territories
EU Exit Amendments
Major Industries
Payment Processing
Correspondent Banking
Financial Services, Funds, Brokering
Trust & Corporate Services
Professional Services
General UK Sanctions Measures
Derivatives
Prohibitions on Central Bank, Wealth Fund, Ministry of Finance
Financial Services
Exchange, Reserve & Asset Management
Exercise: Market & Currency Flows
Session 6: China & Venezuela
US Sanctions On China: Executive Order 14032 Non SDN
Chinese Military Industrial Companies (CMICs)
Prohibition on Securities
Definitions & Treatment of Derivatives
Specific Names
Application of 50% Rule to Subsidiaries
Investment Advisory Services
Venezuela Sanctions & Prohibitions
Government
PdVSA
Central Bank
Access to US Financial Markets
Other Financial Sanctions
Case Study: Hunger Bonds
Case Study: Interactive Brokers
Training Objectives
The course objectives are to analyse and develop a critical understanding of the impact of sanctions on securities, financing and investments within the context of capital markets and wholesale banking products and services.
The course will focus on major sanctions regimes, where there are specific securities, finance and investment sanctions risks, including: EU, US & UK Sanctions on Russia
China & Venezuela
Training Course Summary
The course is designed to improve participants’ awareness and knowledge of sanctions risks in issuing, trading, selling or facilitating securities transactions. It focuses on the specific US & EU sanctions regimes and the practical differences and difficulties in their implementation. The course will be of significant benefit to sanctions specialists, financial crime specialists, and other risk professionals, as well as executives and managers who have a responsibility for managing securities and investments in a range of financial institutions.
Your trainer
Course Trainer · 10 yrs experience
- Financial Crime Compliance Courses
Our securities compliance course instructor is a specialist in investment banking governance, audit, risk, and compliance, bringing extensive international experience to his work. He holds an MBA from Bayes Business School in London and is a Chartered Certified Accountant. He began his career with Price Waterhouse in Kingston, Jamaica, before relocating to London in the wake of the 1986 financial “Big Bang.” Over the years, he has worked with several major financial institutions, including Manufacturers Hanover Trust, Continental Bank, CIBC, and ABN AMRO.
Throughout his career, he has held roles spanning internal audit, product control, risk management, and SOX compliance. His work across major global financial centres has given him deep expertise in regulation, governance, and internal controls across the full lifecycle of investment banking and capital markets products. His experience covers areas such as credit trading and derivatives, asset securitisation and structured finance, foreign exchange and FX options, interest rate derivatives, as well as commodities and treasury operations. In addition, he has taken on leadership responsibilities, playing a key role in developing and implementing strategic initiatives within global banking and markets, alongside delivering large-scale training and cultural change programmes across more than 50 countries.
In his current capacity, he delivers financial crime compliance programmes for leading global banks, including HSBC, Société Générale, SMBC, RBS, Lloyds, Nordea, and Handelsbanken. His training focuses on key areas such as anti-money laundering, sanctions compliance, tax evasion prevention, terrorist financing prevention, and anti-bribery and corruption measures, along with their associated governance frameworks. His programmes are designed for both frontline staff and senior management, reaching audiences across private, corporate, and retail banking sectors in the UK, Europe, Asia, the Middle East, Africa, and the Americas.
He has also served as a Master Trainer on HSBC’s global financial crime training programme and has developed specialised workshops on AML and sanctions with a focus on financial markets, securities, and investment products. His broader experience includes delivering train-the-trainer courses, presenting to US regulators, and providing instruction on audit, conduct risk, operational risk, treasury, Basel III, liquidity and capital management, and ICAAP. Additionally, as an Associate of RSM, he has conducted financial crime and regulatory compliance reviews for institutional clients and is the author of three books, including Clearing The Bull: The Financial Crisis And Why Banks Need A Human Transformation (2012).
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