On Thursday, July 16, ACAMS New York Chapter hosted an event titled Hot Topics in Sanctions, which was sponsored by LSEG Risk Intelligence. The discussion included the following individuals pictured from left to right below: Che Sidanius (Panelist - Global Head of Financial Crime & Industry Affairs, LSEG (London Stock Exchange Group); Sue Eckert (Panelist - Al-Qaida/ISIL Monitoring Team, United Nations); Gurran Kane (Moderator - Executive Board Member, ACAMS NY Chapter); Meryl Lutsky (Opening Remarks - Co-Chair, ACAMS NY Chapter); and Peter Piatetsky (Panelist - CEO, Castellum.AI).
The event began with discussion on how UN Sanctions have historically served as the core of all Sanction requirements across various regimes. This is because UN Sanctions form a legally binding responsibility for UN member states, although the Sanctions imposed by member states are often more well known than the UN Sanction requirements that they stem from. As background to the discussion, the panel also mentioned that as of 2017, Sanctions have increased by 350%. This great increase has put pressure on financial institutions to keep pace with the quickly evolving regulatory environment. Additionally, due to the increased use and investment in Sanctions, countries have begun to include Sanctions and Sanctions evasion as part of their national security strategies (and countries have considered circumvention of Sanctions to be a criminal act).
The discussion then moved to a conversation on information and views on various Sanctions-related hot topics. Panelists agreed that a continuous issue and hot topic is unintended consequences caused by Sanctions. The “de-risking” of conflict zones tends to impact critical humanitarian aid, and similarly, those harmed by Sanctions are often the individuals with the least amount of power and voice. Another concern raised is that there is often not a clear goal associated with Sanctions, which makes it difficult to measure the effectiveness of the Sanction.
At the conclusion of the event, the panelists gave a few key takeaways for the audience:
Public private partnerships enhance the effectiveness of your sanctions compliance program (know your regulators)
Understand the data (including the supplying vendor) behind your Sanctions screening process to find efficiencies
Expect heightened scrutiny around ultimate beneficial owners (“UBOs”) even if an entity is not listed on OFAC’s sanctions list, but is 50% or more owned by an entity or person that is on the list, the same prohibitions apply to dealing with such entity
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