ACAMS Greater Twin Cities Chapter June 2022 Virtual Event: Cutting Off Russia from the West: A New Era of Global Financial Sanctions
Russia’s aggression against Ukraine and the West threatens the very structure of the global order which has been policed by the United Nations since its inception in 1945. Russia as a permanent member of the UN Security Council has violated the preamble and all 11 items outlined in Chapter I of the UN’s Charter, “Purpose and Principles”.
This presentation will; outline and clarify: the significance, complexities, and consequences of the Global Financial Sanctions Regime against Russia for its invasion of Ukraine.
The presentation is focused on assisting Anti-Financial Crime Compliance Practitioners in assessing who and what is sanctioned, and equally important, what the sanction is (block or reject).
Tim will discuss the importance of:
- Understanding these sanction changes
- Knowing the important components of OFAC sanction; Executive Orders, Directives, Annexes and General Licenses (Winddown Periods and Divesting Deadlines)
- Knowing how to stay current when sanctions change
- Augmenting and testing your vendors actions and Testing your interdiction filters
• Request White Papers from your vendors on system functionality and settings
- How to assess new sanctions risk factors from your institution’s perspective:
• client risk, geographic risk, transactional risk, operational/technology risk, and regulatory (examiner) risk
• Crafting risk appetite statements based on historical findings that are specifically designed to reduce consulting and examiner risk
- Russian sanction “evasion typologies” - what we know and what we suspect?
- Training and educating your institutions staff and leadership
The presentation will begin with a quick overview on what compliance practitioners need to understand about Russian sanctions from 2014 as they are still enforcing and have been expanded. It will also look at subsequently applied sanctions including: CAATSA, E.O. 13849, PEESA, E.O. 14039, which also targeted Russian related activities. CAAPTA will be explained, and the advent and challenges of secondary and Menu-Based sanctions will be discussed. Additionally, it will explain how recent seizure of Oligarch assets have involved Russian Sanctions, but were not seized under sanctions authority.
Lastly, why we are likely to see more layers of sanctions both applied and withdrawn as the Russian aggression against the Ukraine and the West evolves.
1 ACAMS Credit
**Please note that ACAMS credit for this virtual event is available to members of the Chapter only.