Author Archives: issanctions

Takeaways from the Process for the 10th Sanctions Package 

Today marks the one year anniversary of Russia’s invasion of Ukraine, and we are still awaiting the EU’s long signaled 10th sanctions package, which was pledged to be a key statement of the resolve of the Union and further demonstration of the effort to hinder Russia’s ability to wage aggression. Pegged by some just lastContinue reading “Takeaways from the Process for the 10th Sanctions Package “

Will Europe Target Privileged Industries in the 10th Sanctions Package?

Pushed by hawkish member states of Poland and the Baltic states, the EU has begun working on the 10th sanctions package with an expectation that it will be ready to enact in time for the one year anniversary of Russia’s invasion of Ukraine on 24 February. The discussions yet again mention banning the import ofContinue reading “Will Europe Target Privileged Industries in the 10th Sanctions Package?”

Key Takeaways from OFAC Settlement Agreement with Danfoss A/S

On 30 December 2022, US Treasury’s OFAC announced its settlement with Danish company Danfoss A/S for causing US financial institutions to violate US sanctions on Iran, Syria and Sudan. The settlement was for over $4 million which was negotiated down from a statutory maximum of almost $22 million as a result of Danfoss’ extensive cooperationContinue reading “Key Takeaways from OFAC Settlement Agreement with Danfoss A/S”

Sanctions Compliance Program- Training

The most frequent questions we receive on sanctions training How should our training be structured? Training is an essential component of your SCP to ensure that employees understand your company’s risk appetite, compliance structure, and policies and procedures used to achieve compliance. We often see that organizations and suppliers of training materials focus on explainingContinue reading “Sanctions Compliance Program- Training”

Sanctions Compliance Program- Testing and Auditing

The most frequent questions we receive on testing and auditing In essence, testing and auditing are variations of the same answer to the question, is our program working as intended and as needed? Testing and auditing are the means for your organization to evaluate the effectiveness of your sanctions compliance program in practice. In termsContinue reading “Sanctions Compliance Program- Testing and Auditing”

Sanctions Compliance Program- Internal Controls

The most frequent questions we receive on internal controls: Policies, instructions and procedures as internal controls  Internal controls are multiple different actions and tools working together to form a comprehensive package of measures which are the means to minimize the sanctions risks to your company. There should be an inherent interplay between the findings ofContinue reading “Sanctions Compliance Program- Internal Controls”

Sanctions Compliance Program- Risk Assessment

The most frequent questions we receive on risk assessment: What is a risk assessment? A risk assessment is the means of identifying areas in your organization’s operations where there is inherent risk for potential sanctions violations or misconduct. Effective risk assessments are conducted regularly or as an ongoing exercise using a defined risk-based methodology thatContinue reading “Sanctions Compliance Program- Risk Assessment”

Sanctions Compliance Program – Management Commitment

Management Commitment means that senior management ensures the organization’s compliance with applicable sanctions programs by promoting a “culture of compliance” within the organization. This means that senior managers ensure that employees are aware of their responsibilities, inspire them to be compliant, and allocate adequate resources to enable the organization to be compliant.