Sanctions Awareness

In this introductory course, we explain why it is so important for firms to understand what sanctions are, what sanctions regimes may apply and how to manage and mitigate the risk of breaching relevant sanctions.

With a very practical focus, this course describes who implements sanctions and why they do that; how these regimes have effect and in what way you and your firm may come within their scope; and how, by taking a systematic and risk-based approach you can manage and control those risks, following recommended best practice.

This awareness-based course is primarily for staff in both the front office and compliance and legal functions.

By the end of this course participants will be able to:

• Explain the purpose and different types of sanctions bodies
• Describe the work of the UN sanctions regimes
• Identify different types of sanctions, including targeted, list-based, narrative and secondary sanctions
• Define the scale, scope and international reach of the US and EU sanctions regime
• Apply UAE sanctions
• Describe and apply an appropriate risk-based approach to identifying and managing sanctions risk

Introduction - What Sanctions are:

• International sanctions
• Commercial and trade sanctions
• Financial sanctions, tariff and non-tariff trade barriers; export controls; dual use goods
• Asset freezes
• Directions to cease business
• Anti-terrorism and non-proliferation

The Key Sanctions Implementing Bodies

• UN Sanctions

• The UN’s role in and approach to sanctions
• Member states and the application of UN sanctions
• UN Sanctioned countries

• US Sanctions

• Office of Foreign Assets Control (OFAC)
• Scope and applicability of US Sanctions
• Specially Designated Nationals
• Sectoral sanctions
• Narrative and secondary sanctions
• The implications of additional sanctions against Russia
• Countries under US sanctions and in what way
• Other: Anti-corruption sanctions, Magnitsky, Blood diamonds, non-proliferation, transnational criminal organisations
• OFAC licences

• UK Sanctions

• The UK sanctions regime and legal backing
• The roles of OFSI, DIT and other bodies
• The types of UK based sanctions and their scope and applicability
• Identifying and reporting breaches

• EU Sanctions

• Scope and applicability
• Sanctioned entities
• Implicit sanctions
• Local enforcement
• Sanctions divergence

Penalties & Enforcement

• UN approach to enforcement
• OFAC global reach
• OFAC penalties
• UK enforcement and penalties

Managing Sanctions Risk

• Sanctions Risk

• The importance of a risk-based approach to sanctions
• Applying Best practice
• Clients and associated parties
• Organisational red flags
• Third party red flags
• Exploratory review
• Screening and media searches

• Ongoing monitoring

• Periodic reviews
• Trigger reviews: Types, analysis, who does what
• Internal reporting: when and to whom

Have the flexibility to deliver your In-House training in-person by one of our trainers at your premises, or virtually via Zoom, Teams or Webex.

Find out more about your Virtual or In-Person training experience below.