Checklist: How to Ensure Compliance with Financial Sanctions Obligations

Responding to the Russia-Ukraine conflict, the UK government has imposed sanctions on Russia. UK/Financial Conduct Authority (FCA)-regulated firms have an obligation to implement and maintain systems and controls to counter the risk that might be used to further financial crime. This includes compliance with financial sanctions obligations within the UK and should also reference other relevant sanctions regimes such as in the U.S., European Union and United Nations. 

The FCA reminds firms that it has the power to impose restrictions and/or take enforcement action where it identifies failings in these controls. Furthermore, the Office of Financial Sanctions Implementation (OFSI) also has the power to levy civil (monetary) penalties for breaches of financial sanctions and, in extreme cases, will work with law enforcement to pursue criminal prosecution.

With the authorities increasing their focus on financial sanctions, we’ve developed a checklist of tasks you need to consider. 

Download Checklist
 

How we help

We have a range of services that help support you in navigating these complicated obligations, let you know of any red flags, and advise on how to remediate them. These include:

• Sanctions screening via ComplianceAlpha's award-winning AML KYC/CIP: Providing timely, automated, ongoing monitoring of 1,500 critical lists, including:
  • 114 sanctions lists
  • 833 watch lists
  • PEP’s list from FATF with over 200 committed countries
  • 500+ adverse media lists
  • 134 fitness & probity lists
  • advanced name-matching algorithms for both individuals and entities. Our data sources consider not only formal changes to the Specially Designated Nationals List in real time, but also measures announced publicly when written evidence from official sources are deemed reliable.  
• Tailored managed services to increase operational efficiencies and cost savings: This solution includes the option to receive full-service support from ACA’s team of experienced technologists and compliance professionals, which includes Certified Anti-Money Laundering Specialists (CAMS). The combination of tech and managed services provides firms with faster, more accurate data screening, ongoing monitoring, remediation, and reporting while increasing overall operational efficiencies and cost savings.
• Compliance advisory services: We specialise in assisting our clients in developing and implementing effective AML practices that meet industry best practices and comply with applicable laws and regulations. 
• Training: Our UK-based office offers two related training courses
  • Financial Crime Prevention training: to help develop a sound knowledge of AML and Market Abuse controls – two topics which feature prominently on the FCA’s current business plan.
  • Money Laundering Reporting Officer: The Role and Responsibilities: provides practical advice and guidance on the responsibilities of the MLRO, what is expected by Regulators, and how those responsibilities can be achieved.
• Cyber, privacy and risk services from ACA Aponix: our advisors are on hand to assist you in reviewing your risk and connections to Ukraine. We offer comprehensive cyber solutions to help provide cybersecurity and technology risk programs, data privacy compliance services, vendor due diligence services, portfolio company oversight, network testing, and advisory.

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