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Sanctions compliance

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Emerging trends in sanctions compliance

Uncertainty regarding Russia sanctions

Russia and Ukraine-related sanctions, including entities on the Sectoral Sanctions Identification (SSI) list create uncertainty in the sanctions landscape.

Create an agile screening program: From list management and governance to technology, today’s sanctions programs must be able to adapt more rapidly than ever before.

Beneficial ownership rule increases complexity

Ambiguous screening standards for minority beneficial owners create a gray area.

Define more granular screening standards: In the post-SSI and beneficial ownership world, banks must identify risk tolerance-appropriate screening standards for screening of beneficial owners, and enhance processes from know your Customer (KYC) to customer due diligence (CDD).

Sovereign Initial Coin Offerings (ICOs)

Governments including Venezuela and Iran are considering the issuance of cryptocurrency tokens to raise funds and potentially circumvent sanctions.

Manage exposure through program enhancements: Banks must limit their exposure to sovereign coins by gathering additional KYC information regarding cryptocurrencies and enhancing blacklists.

Trade sanctions cut across sectors

Traditionally, screening was primarily a consideration for financial services firms. New trade sanctions mean that responsibility now stretches to companies in other sectors, who may be ill-prepared.

New sectors, new models: It is now necessary to implement bespoke programs for companies in industries such as energy, where firms must now grapple with sanctions against the Russian energy industry.

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