Registration, Refreshments and Networking

OPENING REMARKS FROM THE CHAIR

FUTURE OF GLOBAL ECONOMIC SANCTIONS: REGULATORY PERSPECTIVE, ENFORCEMENT FOCUS AND EXPECTATIONS**

• Direction of US, UK and the EU sanctions policy for the next year
• US sanctions policy:
  • Overview of recent significant developments in key US sanctions programmes (Russia, Iran, Cuba, North Korea, Venezuela sanction regimes; “targeted” sanctions; secondary/extraterritorial sanctions; “facilitation”)
  • Countering America’s Adversaries Through Sanctions Act (CAATSA)
  • What can FIs and other companies take away from some of OFAC’s enforcement actions this year? What are some of the trends and pitfalls evidenced by this year’s actions?
• UK sanctions policy:
  • How is the UK’s new international sanctions regulatory architecture evolving? Has Brexit put UK sanctions policy at risk?
  • Unlocking penalty powers: How are OFSI’s new compliance powers are being used
• Outlining EU sanctions policy and priorities for 2018 and beyond

Refreshments and Networking

EFFECTIVELY MANAGING RUSSIAN SANCTIONS

• Enforcement update on US and EU sanctions: are we likely to see enforcement actions against companies violating sanctions targeting Russian companies
• How to prepare and effectively respond to potential “overnight” changes coming your way: what systems must be put into place to avoid engaging in prohibited activities and to ensure that newly sanctioned parties can be quickly added to checks
• Best practices for overcoming challenges related to the project specific nature of the Russian sectoral sanctions and dealing with difficulties for compliance teams to infiltrate

SANCTIONS RISKS RELATED TO IRAN: UK, EU AND US PERSPECTIVE

• Sources of US sanctions law: changes based on JCPOA; executive orders; the snap back risks
• Successfully navigating the complexity of U.S. and/or EU regulations when transacting with Iran
• Do’s and don’ts of making and receiving payments, integrating payment services and facilitating transactions
• Understanding to what extent your company is exposed to certain risks related to Iran sanctions
• What are the practical steps for setting up an effective control framework in a multi-national organisation spanning over various continents once the risks are identified?
• Getting comfort that the controls work effectively (assurance) once the control framework is implemented
• Who should the compliance assurance be reported to once it is done and what are the next steps

Lunch and Networking

LARGE ORGANISATIONS SPEAK ON INTEGRATED APPROACHES AND OTHER CULTURAL MEASURES TO DEVELOP A STRONG GOVERNANCE, RISK AND COMPLIANCE SYSTEM

Senior internal audit and control officers will share their best practices on how they work together with compliance officers on tackling the most critical issues of governance, risk and compliance amid increased levels of expectations and scrutiny by foreign and local regulators and enforcement bodies, key stakeholders and external auditors.

• How often should you carry out a substantive and structured sanctions law risk assessment?
• To what extent should you be conducting pro-active ad-hoc audits?
• What is the scope of sanctions policies for the international business of your organisation?
• How an integrated risk based approach can help your organisation to build a road-map to strong governance, risk and compliance system by helping to anticipate and mitigate potential legal, regulatory and operational risks
• How internal audit and compliance functions can work together to establish corporate culture and drive business forward without compromising its integrity

Sanctions Post Brexit

Refreshments and Networking

DEAR REGULATOR, I HAVE A QUESTION…: Moderated Session**

This year following an overwhelming demand from our audience, we have put together a new, exclusive session, allowing participants to ask questions to OFAC, OFSI and European Central Bank live, anonymously or otherwise.

Networking Drinks

Wind down and sample a selection of drinks as you end the first day by networking, comparing notes and sharing visions with fellow conference attendees around industry trends and developments.

Refreshments and Networking

OPENING REMARKS FROM THE DAY CHAIR

KEY TO SUCCESFUL INVESTIGATIONS AND DEALING WITH AN AFTERMATH OF A HEAVY FINE

• Steering the scope of disclosure: who knew and who had institutional knowledge? How high was the information? Were the jurisdictional risks clearly understood? Local rules of lawyer-client privilege as it applies to internal v external counsel
• Effectively using internal resources. who should be responsible for conducting investigations
• Managing employees: getting the most out of employee interviews – how to persuade employees to cooperate with external counsel
• Managing business partners and third parties during the investigations process
• Remedial actions: managing tension between investigating/ disclosing and remediation/compliance – the privilege of cooperation
• Moving past the investigation and disclosures and finding silver lining when having to go through government investigations
• Recalibrating training and communications strategy: how to ensure proper understanding at a basic level – overcoming challenges with auditing every local site and every local branch
• The importance of engaging middle management
• Deploying artificial intelligence to aid investigation processes

REINFORCING FINANCIAL CRIME RISK MANAGEMENT IN THE SECURITIES INDUSTRY: ISSA FINANCIAL CRIME COMPLIANCE PRINCIPLES (FCCP)

Refreshments and Networking

PREPARING AND ADDRESSING A VOLUNTARY SELFDISCLOSURE

• Making a voluntary disclosure: what are the key issues to watch out for before deciding to go down that route
• “Humanising” your company to the Government: the importance of building relations with the regulator
• Which regulator should you make an initial disclosure to?

COMPLYING WITH INTERNATIONAL SANCTIONS PROVISIONS IN CORPORATE FINANCING AND MANAGING M&A DUE DILIGENCE

• Determining if the sanctions clause you agreed to is stricter than the law requires
• What happens if the sanctions change in a way that conflicts with the clause
• Did you commit your entire corporate family to comply and how do you ensure compliance?
• Identifying and scoping sanctions risk in M&A transactions
• Overlap of sanctions and export control risk in M&A due diligence

Beneficial Ownership: the issue in third party due diligence

• The heightened focus on beneficial ownership identification within CDD
• Ongoing regulatory impact on availability and quality of data sources
• The impact of ownership on Sanctions programmes
• Case study: delivering automated CDD solutions

Lunch and Networking

PREPARE FOR THE UNEXPECTED: SANCTIONS RISKS IN TRADE FINANCE AND EXPORT CONTROLS

• New financial crime risks related to trade finance transactions financial institutions must be aware of (risk assessment; documentation process and application of controls)
• How well do you know your customer? Challenges with obtaining a thorough understanding of your customers’ and their counterparties’ business models
• What’s the challenge when looking at a transaction? Is the transaction in line with what you know about this customer?

FOCUSING ON AML AND CTF CONTROLS

• New powers to law enforcement authorities: what do greater investigation periods mean for financial institutions
• Best practice for detecting and managing the risks of terrorist finance: risk assessment; third party relationships, including correspondent networks; monitoring social media
• Information disclosure and difference in privilege rules across jurisdictions: reporting on suspected irregularities and cooperating with the authorities
• Criminal Finances Bill: Looking at the new legislation through law enforcement and AML lenses

CO-CHAIRS’ CLOSING REMARKS

Refreshments and Networking