Overview
Practical training on UK and Office of Foreign Asset Control (OFAC) Economic Sanctions.
This intensive half-day workshop will help you to understand:
- The OFAC sanctions regime and how and why it applies to businesses in Jersey
- The risks of conducting business with any person appearing on any sanctions list internationally
- Key provisions of US Anti-Terrorism Act provisions and how the Act can be used against businesses in Jersey
- Examples of US enforcement action against non-US banks
Course content
Understanding sanctions regimes
- Bank of England/EU/Jersey
- OFAC
- The extra territorial reach of US sanctions and how they apply to US and non-US persons
- How US sanctions can bite against non-US persons including British citizens working for Jersey financial institutions
Designing a risk-based sanctions compliance regime
- Higher risk areas based on customers, products, services and geography
- What to include in your compliance procedures manual
- Who to screen beyond Ultimate Beneficial Owners (UBOs)
The costs of non-compliance. What do recent cases teach us?
- Lloyds TSB, Credit Suisse, ANZ Banking Group, NatWest
Facilitation risks
- What is and isn’t facilitation?
- Case studies: Registered office, Syndicated lending, Aircraft leasing, Trust and company ownership structures, Banking
Learning outcomes
The workshop will equip you to:
- Identify and prevent facilitation risks
- Detect Specially Designated Nationals (SDNs) and suspect arrangements
- Design a risk-based sanctions compliance programme
- Respond to suspect violations and conduct internal investigations