Reining in on Sanctions Evasion - Managing the Complexity of an Ever-evolving Sanctions Regimen
Sanctions only work when they can be effectively enforced. Especially global Sanctions regimen are hard to track and with that even harder to enforce.
On the other hand, with evolving sanctions like the ones against Russia many companies and financial institutions find it hard to ensure that their business activities are compliant. Fines for non-compliance are high and the reputational risk sometime even higher.
- Setting the stage
- Most common ways to avoid sanctions
- Most common techniques to prevent and detect sanctions evasion
- Sanctions evasion in the U.S.
- Regulators on high alert (FinCEN Alerts, OFAC FAQs, Evasion Networks)
- Policymakers demand regulators’ vigilance
- US Enforcement (KleptoCapture Task Force, related indictments, first legal actions, Treasury targets Networks)
- Sanction evasions in the EU
- EU regulations vs. national enforcements
- Guidance and initiatives from the European Commission (incl. the Whistleblower tool)
- Member states’ law enforcements – one vs. multiple players
- National measures: Germany’s Sanctions Enforcement Act I
- De-risking, humanitarian and food security
- Cooperation of government agencies and international organizations
- The Russian Elites, Proxies, and Oligarchs (REPO) Task Force
- Extensive existing frameworks
- Cooperation among EU member states: the EU Freeze and Seize Task Force
SPEAKERS:
- Matt Moses, Partner, ORRICK
- Alina Nedea, Head of Unit - Sanctions, DG FISMA EUROPEAN COMMISSION
- Helene Dewing-Kapur, Europe Head of Sanctions, HSBC
- Amber Vitale, Managing Director – Financial Services, FTI CONSULTING
- Vincent Affourtit, Partner, HOUTHOFF