Economic Sanctions & Financial Crime

Registration, Refreshments and Networking

Welcome Remarks from Co-Chairs of Day 1

Spencer Chilvers
Head of Export Control Policy
Rolls-Royce (UK)

Nathalie von Taaffe
DMLRO, Head Financial Crime Policy, Advisory & Controls
ICBC (UK)

OFAC and OFSI Share Regulatory Landscape, Compliance Expectations and Enforcement Priorities

Carlton Morris
Compliance Officer
OFAC (USA)

David McLean
Joint Deputy Head of OFSI & Head of Enforcement and Engagement
HM Treasury (UK)

Discussion Leader

Ryan Fayhee
Former DOJ National Export Enforcement Coordinator
Partner
Hughes Hubbard & Reed (USA)

• US sanctions policy:
  • recent policy changes and significant shifts in the U.S. economic sanctions strategy
  • recent OFAC enforcement actions
• An update from OFSI on UK sanctions policy
  • active cases under investigation
  • stepping up UK enforcement activity: what’s on the horizon
• Understanding the extent of cooperation between OFSI and OFAC and top

Countering Exterritoriality of US Secondary Sanctions and Jurisdictional Conflicts

Anna Bradshaw
Peters and Peters (UK)

John Smith
Former Director of the U.S. Treasury Department’s OFAC
Partner and Co-Head, National Security Practice
Morrison & Foerster (USA)

While serving as a top official at OFAC, Mr. Smith was centrally involved in all aspects of developing, implementing, and enforcing U.S. government sanctions requirements. As OFAC Director, he oversaw every OFAC enforcement case against financial institutions and global operating companies. Mr. Smith played a pivotal role as OFAC moved to the center of our nation’s response to the world’s most complex and challenging national security and foreign policy crises, working closely with other governments and multilateral agencies and the private sector.  

• Overview of conflicting extraterritorial US sanctions, rules and regulations
• EU blocking statutes and anti-boycott provisions in relation to Iran on EU and national levels
• Protection against conflicts of law
• How to deal with conflicting regulations when you might face contract liability and termination is not an option
• How to mitigate risks of potential infringement of both sanctions laws and blocking measures?
• Challenging sanctions

Refreshments and Networking

Navigating U.S. and EU Russia-related sanctions

Discussion Leader

Richard Dunmall
Head of Sanctions
Sumitomo Mitsui Banking Corporation (UK)

Armin Stremitzer
Deputy Group Head Financial Sanctions Compliance, Director
Raiffeisen Bank International AG

Roberto Gonzalez
Partner
Paul Weiss

• Focus on EU restrictive measures
• US secondary sanctions provisions under CAATSA
• What’s coming? Planned US Bills with proposed US sanctions
• Scoping “significant transactions” in the context of secondary sanctions
• Pre-emptive risk management action plan regarding sanctions candidates (oligarchs)
• Avoiding sanctions risks in JVs with a Russian SDN as a minor shareholder
• Potential implications of Russian Counter Sanctions on banking industry

NEW FOR THIS YEAR

BIRDS OF A FEATHER Networking Luncheon

Networking Luncheon Be part of informal group discussions with your peers sharing common areas of interest and expertise. Discussions will be held in strict accordance with the ‘Chatham House Rule

Focus on New Iran Secondary Sanctions and Enforcement

Mandy Palmer
Managing Director and Head of Banking, Financing & Securitization Paris-London
Credit Agricole Corporate and Investment Bank (UK)

Discussion Leader

Nicole Erb
Partner, Washington, DC
White & Case (USA)

Karen Walter
Head Compliance Regulatory & Advisory
Allianz SE (Germany)

Nicholas Bentley
Senior Legal Counsel Trade Sanctions
Novartis (Switzerland)

Spencer Chilvers
Head of Export Control Policy
Rolls-Royce (UK)

Chris Po-Ba
Lloyd's
(UK)

• Wind-down risks: Is the termination of agreements your only option? Would a suspension be enough? Could executed contracts, under which only warranty obligations remain, be put dormant?
• Distinguishing how OFAC treats cases with:
  • entities with direct presence in Iran through a subsidiary
  • entities with a JV with an Iranian party
• Executing payments in the environment when financial institutions, insurance companies and their counterparties are derisking in relation to Iran

Performing Internal Investigations that Prepare Your for a Government Investigation

Tyler Hand
Global Head of Sanctions, Interdiction & Anti-Corruption | Global Compliance
Western Union (USA)

Jonathan Poling
Partner
Akin Gump Strauss Hauer & Feld (USA)

• How is global push for privacy enforcement affecting sanctions and financial crime investigations
• Privilege laws and voluntary disclosure policies of EU Member States. Understanding the differences with the US policies
• Scoping specific reporting obligations to OFAC and OFSI. Determining whether legal privilege applies when reporting sanctions breaches
• Corporate criminal liability, proactive self-reporting and personal accountability for non-disclosure. Criminal and civil penalties

Refreshments and Networking

BACK BY POPULAR DEMAND

Dear Regulator, I have a Question: Dedicated Q&A Session

In addition to taking part in the sessions and their extended availability to answer specific questions throughout the conference, Senior Advisors from OFAC and OFSI will take part in this interactive Q&A session providing guidance on specific scenarios. Make sure your questions get answered – prepare your questions well in advance and submit them to Anita Arthur [email protected] (anonymously if you choose to) before the session commences

Closing Remarks for Day 1

Conference Adjourns to Day 2

Early Riser Session: How to Work Effectively with OFAC

Carlton Morris
Compliance Officer
OFAC (USA)

Arrive at the conference early for a unique opportunity to learn how OFAC is structured as well as the best methods to interact with them

Welcome Remarks from Co-Chairs of Day 2

Tassilo Amtage
Director | Financial Crime Compliance & Operational Risk Control
UBS Europe SE (Germany)

Miriam Gonzalez
Partner, Co-Chair | International Trade and Government Regulation Practice
Dechert (UK)

Focus on AML Compliance and Enforcement

Arnaud Romme
Senior Compliance Officer, Specialist Financial Economic Crime, WB Compliance Risk Management – MLRO
ING Bank N.V. (The Netherlands)

Jessica Carey
Partner
Paul Weiss (USA)

Neill Blundell
Head of Corporate Crime and Investigations
Macfarlanes (UK)

• Correspondent banking against the backdrop of the Russian Laundromat and the Danske Bank Case: Will AMLD 5 and 6 help Banks fighting Trade based Money laundering?
• Public UBO registers for companies
• Adapting AML measures and rules to the risks posed by new technologies and industries
• Measures to regulate and tackle terrorist financing risks linked to cryptocurrencies
• AML rules to counter terrorist financing and increase transparency about who really owns companies and trusts
• Enforcement focus
• Cryptocurrencies and cryptoassets: Managing risks of sanctions and AML exposure

BREXIT: The Countdown Begins

Maya Lester QC
Barrister
Brick Court Chambers (UK)

Miriam Gonzalez
Partner, Co-Chair | International Trade and Government Regulation Practice
Dechert (UK)

• Where is the UK’s AML and Sanctions legislation heading post 29th of March, 2019
• Status update on UK Sanctions and Anti-Money Laundering Bill: New risk and compliance expectations
• How does the UK nexus definition apply on EU countries where a UK entity operates on passporting rights?
• How will the UK respond to future changes to AML legislation coming out of EU?

Refreshments and Networking

New UK Sanctions and Anti-Money Laundering Bill in the British Overseas Territories Context

Aki Corsoni-Husain
Partner, Head of Regulatory
Harneys (Cyprus)

• Publicly-accessible UBOs registers: Shedding light on corporate structures by 2020 and beyond
• Hidden beneficiaries and offshore accounts: New risks for UK businesses
• Disentangling complex ownership structures: Tools and techniques for reviewing new client onboarding and CDD procedures

Screening Solutions for Effective Transaction Monitoring

Lena Stenberg Domeij
Head of Compliance
MFEX & Fondab (Sweden)

Neil Whiley
Principal Auditor – Sanctions and Embargoes
Deutsche Bank (UK)

• What kind of transactions are catching the attention of regulators?
• What is sufficient/insufficient when conducting run-based checks on customer transactions
• Screening domestic transactions involving sanctions targets and/or PEPs and other high-risk clients
• How is the obligation to screen against US sanctions applied in local transactions
• Effective solutions for robust transaction monitoring and minimizing false positive alerts
• How far must a company go in due diligencing business partners in a long chain of transactions with indirect dealings where the end user is SDN
• Leveraging AI and regtech solutions to detect suspicions transactions

Drafting and Negotiating Sanctions and AML Clauses and Compliance Provisions in Agreements

Nancy Fischer
Partner
Pillsbury (USA)

Lucy Callaghan
Vice President
Morgan Stanley | Legal and Compliance (UK)

• What sanctions clauses and to what extent should lenders and borrowers include in agreements to protect themselves from OFAC, OFSI and other liabilities
• Defining the scope of sanctions provisions with the view to address reputational and legal risks
• Practical examples of sample provisions to identify the sanctions compliance status of a counterparty
• Illegality provision: is that enough to protect the lenders in case of sanctions breach

Networking Luncheon

The Future of Internal Compliance Procedures

Adam Davidson
Legal Director – International
MRC Global (UK)

Nathalie von Taaffe
DMLRO, Head Financial Crime Policy, Advisory & Controls
ICBC (UK)

Jessica Ramos
Senior Regulatory & Oversight Affairs Expert
EBA Clearing (Belgium)

Discussion Leader

Ryan Fayhee
Former DOJ National Export Enforcement Coordinator
Partner
Hughes Hubbard & Reed (USA)

• Maintaining an effective compliance program despite frequently changing regulation
• How best to train people
• How to communicate with your business
• How to make sure compliance is part of the wider culture

Addressing New Sanctions Risks in Trade Finance and Export Controls

Discussion Leader

Tassilo Amtage
Director | Financial Crime Compliance & Operational Risk Control
UBS Europe SE (Germany)

David Whitehouse
Head of Trade & Export Controls, Group Legal Compliance
Johnson Matthey (UK)

• How do exporters and financial institutions approach sanctions and export control risks in high-risk destinations
• Exporting sensitive goods to high-risk destinations: Licencing requirements for banks
• What does the future of sanctions and export controls in the trade finance context look like?
  • enforcement
  • relationships with regulators

Refreshments and Networking

NEW FOR THIS YEAR

“Test your Knowledge” of Sanctions and AML: An Interactive Quiz based on Real World Scenarios

Michael Zolandz
Chair, Federal Regulatory and Compliance
Dentons (USA)

Significant expansion of global sanctions coupled with a massively increased focus on enforcement, are forcing businesses and financial institutions to escalate sanctions and AML controls right to the top of risk management agendas. Yesterday’s knowledge is not enough to protect you today. Wrap up this year’s event with this informal and highly interactive session recapping major regulatory, legal and compliance developments affecting your day-to-day operations.

Closing Remarks from the Conference Co-Chairs

Conference Ends