Helping you address known and emerging sanction risks

Sanctions

When dealing with sanctions, the tendency is to focus solely on sanctions screening. However, global operations, supply chains and international payments and trade are nowadays exposed to an ever-increasing scope and complexity of sanctions-related risks.

With more stringent supervisory focus and increasing fines expected, adopting a robust sanctions compliance programme that goes beyond sanctions screening has become a must. Maintaining regulatory compliance and mitigating the risk of engaging with sanctioned parties can become key to avoiding disruption and operational inefficiencies. In practice, this is also being driven by interaction with other subject persons such as banks and financial institutions.

How can PwC help?

Our FCC team at PwC can help your organisation manage current and emerging sanctions risks in several ways across different sectors.

We can assist in the development of a specifically tailored sanctions compliance programme addressing legal and regulatory requirements and obligations, and instilling the confidence and comfort to carry out international operations effectively and efficiently.

We have developed a sanctions compliance programme based on the following core elements:

Sanctions Framework

Providing you with a sanctions framework evaluation questionnaire, to inform a sanctions risk assessment based on a tailored methodology, which will enable you to quickly detect any risk-based shortcomings within your sanctions framework;

As the regulatory landscape keeps evolving rapidly, managing AML/CFT risks remains centre stage.

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Ensuring real-time and post-transaction monitoring systems are working effectively remains a key challenge.

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Given their prevalence, bribery and corruption have become a key financial crime risk faced by businesses, and ensuring honest and transparent dealing has become an important priority.

In this fast-paced world, being vigilant with respect to the possibility or suspicion of fraud has also become increasingly important.

2 Min Read 19/11/24

Sanctions Compliance: Stay ahead of the curve

The 14th Sanctions Package, published by the EU Council on 24 June 2024, underscores the need for vigilance regarding sanctions, especially those linked to the Russian war in Ukraine. The Package introduces restrictions on Russian LNG projects, bans on importing Russian LNG and helium, and sanctions on Russian banks and crypto asset providers. It also includes measures related to aviation, maritime transportation, intellectual property rights, and funding to Russian entities. Compliance mechanisms are essential to manage legal and reputational risks.

2 Min Read 04/11/24

The Instant Payments Regulation – How prepared are you?

The Instant Payments Regulation (IPR/the Regulation) requires all payment service providers (PSPs) to send and receive euro payments within seconds, on a 24/7 basis, across the EU. The key dates include 9 January 2025 with respect to receiving instant payments, and 9 October 2025 for sending the same and implementing payee verification. The Regulation also raises AML/CFT compliance concerns due to rapid transaction processing times, necessitating daily sanctions screening and real-time transaction monitoring.

2 Min Read 08/10/24

AI and transaction monitoring: The future of financial surveillance

AI and machine learning enhance transaction monitoring by improving efficiency and detecting overlooked financial crime patterns. However, challenges include explainability, bias, and "AI hallucinations," where models produce unreliable outputs. Organisations must regularly test AI models, ensure transparency, and address biases to maintain compliance and improve the system’s effectiveness.

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Contact us

Chris Mifsud Bonnici

Partner, PwC Malta

Tel: +356 79757005

Mirko Rapa

Tax Partner, PwC Malta

Tel: +356 2564 6896

Mark Lautier

Partner, PwC Malta

Tel: +356 2564 6744

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Sanctions

How can PwC help?

Sanctions Framework

Strategy

Sanction Screening

Reviewing Sanctions

Bespoke Training

Independent Testing

Organisation implementations

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