ABOUT

The Sanctions Screening and Investigations Training (SSIT) Programme presents an optimal opportunity for Anti-Money Laundering (AML), Counter-the-Financing of Terrorism (CFT), and financial crime professionals to become fully versed in global sanctions screening and investigations frameworks and practices. In practice, the underlying simplistic objectives of sanctions screening translate into a highly operationally complex framework of sanctions screening policies, practices, programmes, and technologies, which modern sanctions professionals must be highly adept at not only understanding, but also effectively implementing within both small and larger enterprises. 

This requires a highly conversant knowledge of global sanctions frameworks, multi-jurisdictional legislative requirements, automated work-flow management, utilising content-rich user interfaces, and operational knowledge of an array of global sanctions watchlists. Firms must also be adept at implementing sanctions screening programmes and technologies that provide highly accurate and contextual flags and indicators, whilst also minimising false positive alerts. The SSIT Programme has been specifically designed and researched in order to train delegates in all the most relevant sanctions areas required by firms, in order to implement and update modern and effective sanctions screening programmes internally. 

TRAINING PROGRAMME

SESSION 1: A Review of Sanctions Screening and Sanctions Screening Programmes

·     What are Sanctions and Politically Exposed Persons (PEPs)? Definitions of Sanctions; Authority and Influence; Contextual PEP Relationship and Vulnerabilities. 

·     Sanction and PEP Lists; PEP and Sanction Screening; Relatives and Close Associates (RCA) Screening; Know Your Customer (KYC) and Customer Due Diligence (CDD) Processes; Enhanced Due Diligence (EDD) Process.

·     Sanctions Screening Programmes; Publicly Available PEP Lists (Accuity; Dow Jones Watchlist; WorldCheck; WorldCompliance); Electronic Anti-Money Laundering (AML) and Counter-the-Financing of Terrorism (CFT) Electronic Monitoring Platforms.

·     Penalties for Sanctions Violations; Fines and Reputational Damage for Non-Compliance; Risk-Based Approach (RBA) to Sanctions Screening v. Strict Liability Nature of Sanctions Compliance.

SESSION 2: Global Sanctions Lists and Frameworks

·     Sanctioning Bodies (Sovereign States; Regional Institutions; International Organisations): Government Economic Sanctions Lists; 

·     United Nations (UN) Sanctions; United States Office of Foreign Assets Control (OFAC) Treasury Department Sanctions; European Union (EU) Sanctions; EU Consolidated List of Sanctions; HM Treasury Sanctions List; Office of Financial Sanctions Implementation (OFSI) Financial Sanctions: General Guidance; Monetary Penalties for breaches of Financial Sanctions: Guidance.

·     Ownership and Control of Sanctioned Entities; Individual Relationships and Sanctioned Entities; 

·     Specific Named Entity Sanctions (e.g. States; Organisations; Individuals) v. Narrative and Sectoral Sanctions (e.g. Specific Sectors; Prohibition of Specific Activities).

SESSION 3: Sanctions Screening, Best Practices, and Practical Applications

·     Preparation of Customer Data; High Quality Sanctions Data; Sanctions Policies; Transaction Screening; Name Screening (Periodic; Ad Hoc); Lookback Transaction Reviews; Wolfsberg Guidance on Sanctions Screening; Sanctions Screening Technologies.

·     Sanctions Screening and Investigations; Case Management and Audit; Investigations Methodology; Responsible Persons; Internal Controls; List Management and Configuration; Official Regulatory Lists; Third-Party PEP and Sanctions Lists; Internal Confidential Lists; Reference Data Screening; Testing.

·     Sanctions Operational Challenges; Sanctions Evasion Strategies; Corporate Structures and Anomalies; Sanctions and Stripping; Definition of Stripping; Institutional Stripping; Customer Stripping; Stripping Case Study (ZTE Corporation, United States Dollar (USD) $1.9 Billion Settlement, 2017; Red Flags).

·     Sanctions and Legal Liability (Criminal and Civil); Sanctions and Personal Liability (Criminal and Civil); the Enforceability of Non-Disclosure Agreements (NDAs) and Personal Liability.

SESSION 4: Case Studies and Practical Applications

·     UN Sanctions Case Studies: (1) Al Qaeda and the Taliban, 1999; (2) Sanctions against Iran; (3) Sanctions against Iraq, 1990; (4) Sanctions against Ivory Coast, 2004; (5) Sanctions against Liberia; (6) Sanctions against North Korea; (7) Sanctions on Sudan).

·     Sanctions Legal Case Studies: (1) ABN Amro, 2005; (2) Mabey and Johnson, 2009; (3) Lloyds TSB, 2009; (4) Barclays PLC, 2010; (5) Royal Bank of Scotland Ltd, 2010; (6) OFAC and MID-SHIP, $871,837 Fine Iran Sanctions Violations, 2019.

·     Sanctions Case Studies: (1) US Sectoral Sanctions, 2014; (2) US Economic Sanctions against Russia, 2014; (3) EU Economic Sanctions and Russia; (4) EU Sanctions and the Ukraine; (5) Sanctions and Iran; (6) Sanctions and Syria. 

·     Internal Technology Build v. Software Solutions; Watch List Filtering and Sanctions Screening Solutions: (1) Nice Actimize (Name Matching Analytics; Multi-Jurisdictional Screening; Intelligent Scoring; Alert Consolidation); 2) RDC Smarter Screening (KYC/AML Compliance; PEP Databased; Sanctions Screening; Sanctions Connect). 

EXPERT TRAINER

Rodrigo Zepeda is Co-Founder and Managing Director of Storm-7 Consulting. He is an expert consultant who specialises in derivatives and banking and financial services law, regulation, and compliance. He is an expert in a very broad range of regulatory compliance frameworks such as FATCA, the OECD CRS, MiFID II, MAD 2 MAR, PSD2, CRD IV, Solvency II, OTC Derivatives, CCP Clearing, PRIIPs, BRRD, AML4, and the GDPR. He holds a LLB degree, a LLM Masters degree in International and Comparative Business Law, and has passed the New York Bar Examination. He was an Associate (ACSI) of the Chartered Institute for Securities & Investment from 2004 to 2014 and is now a Chartered Member (MCSI). He has created and delivered numerous conferences and training courses around the world such as ‘FATCA for Latin American Firms’ (Santo Domingo, Dominican Republic, Panama City, Panama), ‘MiFID II: Regulatory, Risk, and Compliance (London), and ‘Market Abuse: Operational Compliance’ (London), ‘AEOI (FATCA & CRS)’ (London, Lebanon, Dubai, Malta, Manama, Bahrain); AML/CFT: Operational Compliance (Dubai, London); MLRO: Operational Compliance (London).

He has also delivered numerous In-House Training Courses around the world to major international financial institutions such as The Abu Dhabi Investment Authority (MiFID II: Operational Compliance, Abu Dhabi, the United Arab Emirates); the United Nations Principles of Responsible Investment (MiFID II: Final Review, London); CAF, the Development Bank of Latin America (Swaps and Over-the-counter Derivatives, Lima, Peru); Eurex Exchange (CCP Clearing, Risk Management, Recovery and Resolution, Eschborn, Germany); European Energy Exchange AG (CCP Clearing, Risk Management, Recovery and Resolution, Leipzig, Germany); Rothschild Investment Management (UK) Limited (AEOI (FATCA & CRS), London); Resolution Life (AEOI (FATCA & CRS, London); CCP Clearing, Risk Management, Recovery and Resolution; Bethmann Bank AG (MAD 2 MAR, Frankfurt); Saxo Capital Markets (MAD 2 MAR, London); and Invesco Management, S.A. (AML/CFT, Henley); Validus Risk Management (OTC Derivatives, Eton).

For 2019 he has created some of the most cutting edge training courses available on the market today, including Artificial Intelligence in Banking and Financial Services; Supervisory Technologies (SupTech); The European Margin Rules; The 2018-2020 Collateral Paradigm; AML & CFT Advanced Practitioner; Virtual Currencies, AML, CFT: Operational Compliance; and Behavioural Persuasion Masterclass. He is a Reviewer for the Journal of Financial Regulation and Compliance and has also published widely in leading industry journals such as the Capco Institute’s Journal of Financial Transformation, the Journal of International Banking Law and Regulation, as well as e-books on derivatives law. Noted publications include “Optimizing Risk Allocation for CCPs under the European Market Infrastructure Regulation”; “The ISDA Master Agreement 2012: A Missed Opportunity”; “The ISDA Master Agreement: The Derivatives Risk Management Tool of the 21st Century?”; “To EU, or not to EU: that is the AIFMD question”; and “The Industrialization Blueprint: Re- Engineering the Future of Banking and Financial Services?”.

Disclaimer

ISDA® is a registered trademark of the International Swaps and Derivatives Association, Inc., and Storm-7 Consulting Limited is neither sponsored by nor affiliated with the International Swaps and Derivatives Association, Inc. (ISDA), and the public is hereby informed that Storm-7 Consulting Limited holds no commercial, private, or other relationship with ISDA.