Sanctions Masterclass with Justine Walker
Risk Managing Humanitarian Payments into High Risk Conflict and Sanctioned Environments

  • When: July 9, 2020
  • Time: 9:00 AM – 10:20 AM EST
    2:00 PM – 3:20 PM BST
    9:00 PM – 10:20 PM HKT
  • Level: All

As identified by the United Nations – climate change, economic stress plus protracted and often intensifying conflicts are driving global humanitarian needs to unprecedented levels. In the coming years, these trends are likely to increase vulnerability, putting millions more people at risk of being pushed into humanitarian crisis. Many of today’s humanitarian emergencies are characterized by the presence of wider parallel risk considerations. These include UN/US/EU sanctions and restrictive measures, presence of armed actors, terrorist ideologies, limited payment transparency and wider concerns such as corruption, fraud and money laundering.

Consequently, how to structure humanitarian activities and the processing of related funds without violating sanctions and related regulations is a major dilemma for all stakeholders, including governments, donors, humanitarian organizations and financial institutions.

Drawing upon recently issued risk-management guidelines, this masterclass will explore how banks, humanitarian organizations, donors and sanctions authorities can collaborate to deliver much needed aid. The session will offer a deep insight into the Syria context but will also offer transferable tips to other high-risk jurisdictions where sanctions, conflict and terrorist financing concerns are prevalent such as, Venezuela, Iran, DPRK, Somalia, Sudan and Yemen.

Learning Objectives

  • Understanding how humanitarian actors operate, their financial access needs and control environment
  • Reviewing the key legal and regulatory context relevant to the movement of humanitarian funds into sanctioned and highly complex risk environments 
  • Ascertaining who will benefit from a payment or service provided, including approaches to screening and due diligence
  • Considering key factors on whether funds are being made available to a designated actor, including the thresholds for determining ownership and control
  • Utilizing humanitarian exemptions, including policy intent and scope, how to submit a license request, overcoming common challenges in the practical application of US and EU exemptions
  • Applying international guiding principles for how sanctions authorities, donors, banks and humanitarian actors can effectively and safely work together to mitigate sanctions violations and promote transparent humanitarian payment corridors into highly complex sanctioned jurisdictions

This Masterclass will be delivered in a teaching style and will draw upon real-life examples and emphasize practical applications for ensuring compliance.  The session will be presented live, allowing for question-and-answer sessions, and will also be recorded for on demand access.

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Presenters

Crespi
  • Roberto Crespi

  • Legal Officer, Sanctions Unit
  • CDG FISMA, European Commission

Bio

Roberto Crespi is a Legal Officer in the Sanctions Unit of the Directorate-General for Financial Stability, Financial Services and Capital Markets Union (DG FISMA), European Commission. Prior to that, Roberto worked as a lawyer in British law firms in Italy, United Kingdom and Belgium. He also worked as legal specialist at the European Union Intellectual Property Office in Alicante, Spain.

He is fluent in English, French and Spanish, in addition to his native Italian. Roberto is a fully qualified Italian lawyer (avvocato) admitted to the Bar of Milano, Italy.


John E. Smith
  • John E. Smith

  • Partner
  • Morrison and Foerster

Bio

John E. Smith served as the Director of OFAC, as well as its Deputy Director and Associate Director, for 11 years before joining MoFo in July 2018. Concurrent with serving as OFAC Director, Mr. Smith also served as acting Under Secretary for the Office of Terrorism and Financial Intelligence at Treasury (January 2017 to June 2017). Mr. Smith has overseen the U.S. government’s economic sanctions efforts, imposing sanctions on heads of state, countries, and illicit actors; conducting enforcement actions against dozens of major financial institutions and companies around the world; and developing innovative sanctions enforcement policies to address evolving U.S. national security priorities. Mr. Smith has also supervised the investigation, preparation, and settlement of cases for hundreds of millions of dollars. Mr. Smith is co-head of Morrison & Foerster’s National Security practice and was named by Global Investigations Review (GIR) in November 2019 as one of the most respected Washington, D.C.


Justine Walker
  • Dr. Justine Walker

  • Head of Global Sanctions and Risk
  • ACAMS

Bio

Until December 2019 Justine was the Director of Sanctions Policy at UK Finance. The former chair of the European Banking Federation Sanctions Expert Group, a position she held from 2015 until December 2019, Justine has held specialist policy positions in the United Kingdom at the Financial Services Authority and the Treasury’s Counter Terrorist and Proliferation Financing Branch. She has further acted as an International Monetary Fund advisor on the Nigerian anti-money laundering and counter-terrorist financing capacity building program. Formerly based in Central Asia with the United Nations, she has also worked on programs surrounding weapons and drug trafficking, corruption and terrorist financing, and has served as a national expert on the financing of weapons of mass destruction matters.

Justine has extensive experience of working with foreign governments, international bodies and financial institutions on cross border sanctions matters. This includes acting as an independent expert to the UN and other bodies on the promotion of payment channels in support of permissible international humanitarian activity within sanctioned and fragile jurisdictions, particularly Syria. On behalf of the Alliance for Financial Inclusion and under the auspices of the German G20 Presidency, she prepared the special report on access to finance for forcibly displaced persons.

Within ACAMS Justine is tasked with leading critical industry and public-sector relationships, including engagement with key international bodies and think tanks. She holds a Ph.D. from the University of St. Andrews and an M.Sc. from the University of Edinburgh.


Mark Nakhla
  • Mark Nakhla

  • EVP of Research
  • Kharon

Bio

Mark is responsible for the integrity and strategic direction of all Kharon research for terrorism and Middle East-related sanctions programs. Mark has deep domain expertise on the activities of terrorist support networks and other groups targeted by international sanctions. Mark served as a sanctions officer at the US Treasury Department Office of Foreign Assets Control (OFAC) between 2002-2005 and 2012-2013 investigating terrorist groups and their networks of financiers and facilitators in the Middle East, Asia and beyond. Mark previously served at the US Department of Defense as a Middle East policy adviser, and at Booz Allen Hamilton, where he focused on strategic research and policy planning.


Roland Pearce
  • Roland Pearce

  • Director Corporate Bank Charites Team
  • Barclays

Bio

Roland Pearce is a Director on the Corporate Bank Charites Team at Barclays specialising in providing corporate banking services to large domestic and international charities. In particular, he specialises in supporting humanitarian aid and economic relief charities.

Roland has been a Relationship Director since 2011 and has significant experience in supporting the humanitarian aid sector, which tends to operate in high risk and sanctioned countries. As such, he has much experience at helping clients deliver aid programming, such as supporting refugees and those most in need in Syria and bordering countries, and in getting funds to difficult locations. Roland regularly attends and speaks at various events and conferences on the topic of financial crime governance in the context of humanitarian aid delivery.


ACAMS Sanctions Masterclass Series

To keep compliance professionals informed of essential developments in the ever-dynamic world of sanctions, and for those in various areas who wish to learn more about sanctions, or professionals new to the field, ACAMS brings to you the Sanctions Masterclass Series.

Led by Justine Walker, ACAMS Head of Global Sanctions and Risk, these Masterclasses follow a curriculum shaped by members of the ACAMS international sanctions compliance task force. The master class series will provide a deep dive into some of the most challenging sanctions issues, using real-life examples and emphasizing practical applications for ensuring compliance.