London Forum on Global Economic Sanctions

Registration and Breakfast

Co-Chair’s Opening Remarks

Tassilo Amtage
Director Financial Crime
UBS (Germany)

Susan Leddy
Senior Legal Counsel, Group Operations, Director, Legal & Compliance
Swiss Re (Switzerland)

EU Companies Share Top Priorities for 2020: Juggling Future Business Opportunities Whilst Mitigating Significant Sanctions Risks

Tassilo Amtage
Director Financial Crime
UBS (Germany)

Jonathan Burke
Chief Sanctions Officer
Citibank (UK)

Helene Dewing-Kapur
Europe Head of Sanctions
HSBC (UK)

• What should European Multinationals be doing to prepare for secondary sanctions by the US to mitigate risks of being caught by their extensive extra-territorial reach
• Benchmarking your processes and tools: facilitating identification, collection, scoring
• Making informed decisions on essential components of risk assessments based on regulators expectations
• Scoping your key sanctions risks exposure: geographic, industry, government
• Probing your weak spots and uncovering new red flags for activities, transactions and schemes ensuring your protocols are constantly evolving based on changing risk profiles

Networking Break

What’s Next: Post EU Exit: The Impact on Both UK and the Rest of the World

Maya Lester QC
Brick Court Chambers (UK)

• POST BREXIT: Understanding the impact on your sanction’s regime
• What’s in the pipeline for trade operations in the EU
• What measures should be in place within your organisation
• Preparing and strategizing for the changes in your supply chain
• How the UK will enforce sanctions measures and other areas where information about sanctions may be shared

The Future of Iran Sanctions: New Risks and Operational Challenges Assessing the Extraterritorial Effects of EU Blocking Measures and INSTEX

Hera Smith
Senior Compliance Officer – Sanctions & Embargo
Danske Bank (Denmark)

Nancy Fischer
Partner
Pillsbury Winthrop Shaw Pittman (USA)

Zia Ullah
Partner
Eversheds Sutherland (UK)

Henry Smith
Partner
Control Risks (UK)

• Assessing the extra-territorial effects of US secondary sanctions and the EU Blocking Statute post JCPOA
• Enforcement implications for European entities and individuals
• Mitigating risks within immediately after the “wind down period” – response times and contractual obligations
• Structuring deals whilst avoiding regulatory conflicts
• Executing payments when financial institutions, insurance companies and their counterparties are de-risking in relation to Iran
• INSTEX: How can this enable companies to do business with Iran and has it achieved its stated purpose

Networking Luncheon

Heightened Scrutiny on Transportation Sanctions Risks: New Shipping Advisories and Aviation Sanctions Compliance

Chris Po-Ba
Senior Manager, Compliance and Financial Crime
Lloyds (UK)

Lloyd Meadows
Senior Sanctions Advisor
Standard Chartered Bank (UK)

• OFAC’s expectations for screening the operations of every vessel you are doing business with in the maritime supply chain: banks, energy traders, bunker service providers
• What amounts to a risky transaction in relation to the purchase, acquisition, sale, transport or marketing of a product i.e. petroleum
• How to effectively implement the risk mitigation measures via insurance, verifying cargo origin, reviewing documentation, KYC
• Updating your compliance controls to account for specific types of vessel behaviours that are red flags seen through deceptive shipping tactics

Recent Developments from the US: OFAC Enforcement and Compliance Priorities

Nancy Fischer
Partner
Pillsbury Winthrop Shaw Pittman (USA)

Rachel M. Dondarski
Chief, Regulated Industries Oversight and Evaluation
Sanctions Compliance and Evaluation Division Office of Foreign Assets Control (OFAC) U.S. Department of the Treasury

Networking Break

Complying with Increasingly Complex Reporting Requirements: Blocked, Unblocked Property and Rejected Transactions and More

Gaelle Maquignon
Compliance Governance Specialist
Allianz Global Corporate (UK)

Thomas Koffer
Global Head of Anti-Corruption & Economic Sanctions Compliance
Credit Suisse (USA)

Michael Zolandz
Partner
Dentons (USA)

• Who is subject to reporting obligations and how far does it extend?
• Demystifying which transactions should be blocked and which should be rejected
• Which underlying transactions are prohibited and should not be processed
• Providing effective systems and controls for the reporting of information concerning potential breaches, assets freezing and designated persons
• Meeting the guidelines and staying compliant with OFAC and OFSI

Audience Exchange on Sanctions Clauses: Protecting Your Organisation Through Stringent Contractual Provisions

Laurence Coman
Sanctions & Financial Crime Legal Counsel, Director
Credit Agricole (UK)

Michael Lyons
Partner
Clifford Chance (UK)

• What forms of protection should be included into contracts and transaction documents to cover current and future sanctions? Drafting and negotiating tips
• How far can a sanctions clause protect you from having to perform your contractual obligations?
• How a sanctions clause should be clearly worded and how to ensure a common intention is established amongst all parties to the contract

Drinks Reception

End of Day One

Registration and Breakfast

Co-Chair’s Opening Remarks

In House Compliance Think Tank: Key Components of an Effective Sanctions Compliance Programme and Staying Compliant with New OFAC Guidance

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

Heather Sroka
Senior Corporate Counsel
DocuSign (USA)

Julie Cooper
International Trade Compliance Manager
Spectris (UK)

• Creating synergies between regulatory compliance, risk and finance functions to respond effectively to rapid global and national regulatory changes
• Value from a compliance programme within a UK, US and European context
• Best practices for monitoring potential legislation and potential new targets
• What processes or controls should be enhanced as a result of recent enforcement actions/regulatory developments?

Networking Break

Voluntary Disclosures Best Practices: How to Meet Government Requirements and What to Disclose

Diego Marquez
Senior Counsel – Economic Sanctions and International Trade Compliance
GE (USA)

Neil Whiley
Vice President: Principal Auditor and Anti-Financial Crime
Deutsche Bank (UK)

Thomas Littlechild
Senior Counsel
Wells Fargo Bank (UK)

• What to disclose, to whom and when under multiple set of laws and regulations?
• Key considerations under suspected breaches and multiple parties
• Identifying names under sanctioned entities where a blocked person owns 50% or greater interest
• Understanding the global penalty matrix under the multi-faceted regulatory regimes

Focus on Russia Sanctions: The Latest Developments for Staying Compliant with Primary, Secondary, Sectoral and New CounterSanctions

Svetlana Zarubina
EMEA Regional Head of Sanctions
UBS (UK)

Adrian Muller
Senior Manager Global Sanctions Strategy
Western Union (Lithuania)

Armin Stremitzer
Deputy Group Head Financial Sanctions, Group Compliance
Raiffeisen Bank (Austria)

Daniel Hudson
Partner
Herbert Smith Freehills (UK)

• Latest changes to EU Russia sanctions and the impact of new Russia counter-sanctions
• Classification of sanctionable activity: comprehensive, list-based, sectoral and secondary sanctions
• The imposition of secondary sanctions under CAATSA and EU actions comparable
• The impact of the CBW Act 2nd round sanctions
• Navigating the areas of overlap with sanctions regulations: who has primary authority over your transactions and shared jurisdictions

Networking Luncheon

China: Deep Dive into Huawei Case Study and Meeting Higher Compliance Expectations for Your Asian Operations

Paige Rivas
Director Trade Compliance
Larkin Trade International Associates (China)

Roger Matthews
Partner
Dentons (UK)

• Developing a strategy from a European perspective
• China’s extra-territorial elements: what is their reach and the complexity of the landscape
• Sanctions risk measures with Huawei in light of trade relations with the US and EU
• State of play of the EU Dual-use export control review and its intersection with sanctions

Global Considerations: Successfully Navigating the Conflicting Multi-Jurisdictional Sanctions Regime

Fintan Byrne
Chief Compliance Officer
CurrencyFair.com (Ireland)

Eric Rudolph
Senior Director
Export Controls and Sanctions Practice, FTI Consulting (USA)

Judith Akinosho
Global Head of Compliance
S&P Global Platts (UK)

• Comparative analysis of different sanctions regimes and the key areas of when they come into conflict
• Reconciling conflicting legal requirements while still taking advantage of commercial opportunities
• Streamlining your approach to meet local requirements and securing approvals
• Global trends in enforcement

Networking Break

Increasingly Sophisticated Sanctions Evasion Schemes: Blockchain, Cryptocurrency and FinTech Grego

Gregory Lisa
Partner
Hogan Lovells (USA)

• Current sanctions evasion methods: exchanges to pass KYC, darknets, privacy coins, tumblers and mixers
• Understanding regulators priorities and parameters for good practice when handling new financial crime risks
• The scope for financial and criminal liability for direct sanctions violation or enabling sanctions evasions using cryptocurrencies
• Protocol to identify potential high-risk customers or third parties
• Best practices: risk rating framework preventing customers from certain countries from opening accounts

Spotlight on Emerging Territories: New Sanctions Developments on Venezuela, Turkey, Japan, North Korea and Cuba

Ben Wood
EMEA Sanctions Head
Nomura (UK)

Susan Leddy
Senior Legal Counsel, Group Operations, Director, Legal & Compliance
Swiss Re (Switzerland)

Edward Rubinoff
Partner
Nelson Mullins Riley & Scarborough LLP (USA)

• What are the new restrictions, definitions and designations of companies?
• Do’s and don’ts of making and receiving payments, integrating payment services and facilitating transactions
• Effective use of general licenses across sanctions programs with specific focus on emerging territories
• What amounts to “sufficient” due diligence and what red flags should you be looking for when conducting checks on multiple parties
• Turkey: The risks to your trade of new sanctions imposed under the Trump Administration

End of Forum