Financial Institutions & Sanctions Investigations - A Best Practice Guide

Introduction

In an era when international sanctions have developed almost weekly to respond to the ever-changing situation in Russia and Ukraine, it is now clear that international regulators are turning their attention to compliance and, importantly, enforcement.

It is therefore imperative that in-house counsel, compliance officers, MLROs and senior HR professionals within the financial services sector understand how to effectively conduct an internal sanctions investigation and, where appropriate, manage regulatory interactions.

This new virtual classroom seminar will draw on the private practice, in-house and government experience of the HFW sanctions team to provide a clear route map to undertaking investigations.

The session will consider the immediate steps required to safeguard data, staff and the investigation itself, provide key legal updates on privilege and regulatory engagement and look at the specific considerations of which the financial services sector needs to be aware.

It will also address how best to mitigate against future issues.

What You Will Learn

This live and interactive course will cover the following:

• Introduction - overview of the webinar
• Key, practical aspects of an effective investigation:
• Investigation committee
• Scoping
• Document preservation
• Internal and external communications
• Independent legal advisers
• HR issues
• Regulatory exposure
• Potential penalties
• Regulatory reporting
• Remediation
• Digging deeper - legal and regulatory considerations:
• Privilege and professional secrecy
• OFSI, OFAC and European regulators - information sharing
• Sanctions in an FI context:
• Correspondent banking relationships
• Key learning from regulatory enforcement
• Red flag typologies
• Identification - Customer and transaction screening v other routes to risk identification
• FCA Review of Sanctions systems and controls:
• Findings
• Recommendations
• Future mitigation

Recording of live sessions: Soon after the Learn Live session has taken place you will be able to go back and access the recording - should you wish to revisit the material discussed.