Violations of commercial/sectoral sanctions

> Circumvention schemes and enforcement cases (OFAC, SECO, EU)
> Document review (transport, customs, sales contract, banking documents…)

DETECTING COMMERCIAL SANCTIONS CIRCUMVENTION SCHEMES

Violations of commercial sanctions rules: lessons learned from enforcement cases (i.e. OFAC, SECO and the EU)

• Key cases and patterns
• From root causes of violations to how violations surfaced and were handled
• What authorities are really punishing? From Russia and circumvention via third-countries, dealings in sanctioned sectors, to data and screening.
• What is a significant payment under E.O. 14114 – how to define it?
• Understanding the complexity through real cases from the banking and financial industry highlighted by the OFAC, the EU and some overall lessons learned by SECO.

Circumvention Schemes : How do they function? How to detect them?

• Sanctions schemes typology
• Explanation of the different sanctions circumvention schemes operate currently
• What unites such schemes and what is different about them?
• What does a compliance officer need to know to detect risks of sanctions circumvention?
• Detecting specific sanctions circumvention schemes:
• What information is typically available within a bank of one of the involved entities?
• What are the red flags and how can you obtain information about the other pieces and links of the whole scheme, to understand that there is a circumvention which is attempted / operated?
• What information may not be readily available to compliance officers?
• How to deal with the issue of limited information availability to determine the existence of a sanctions circumvention scheme?
• Practical examples illustrating sanctions circumvention schemes, associated red flags and detection techniques

DOCUMENT REVIEW: transport related document, CIS documents (official, banking…)

Explanation of transport related documents: Certificates of Origin, Bills of Ladings and Customs documentations

• What to look for
• How to detect forged documents, possible frauds and indicia of circumvention of sanctions

Document Review: issues and challenges, redflags, methodology, examples

• Forged documents, falsified documents
• Reviewing contracts: sales contracts, transport contracts
• Reviewing official documents/ / CIS official documents: customs documents, passports
• Reviewing business document / CIS business documents: financial statements, reports
• Reviewing banking documents / CIS banking documents