It is a matter of record that national governments and international organisations, such as the European Union and the United Nations, are prepared to impose financial sanctions in order to influence national governments or to inhibit individuals and organisations.

The challenges
Different sanctions regimes have different breadth and reach. For example the United States Office of Foreign Asset Control (“OFAC”) prohibits almost all US Dollar transactions with Cuba but is silent with regard to Somalia. By contrast, the Bank of England and the European Union do not apply sanctions to Cuba but do place restrictions on Belarus.

More challenging still are the approximately 4000 Specially Designated Nationals (“SDNs”) cited by OFAC as being subject to financial sanctions. These SDNs include many of the world’s most notorious terrorist and narcotics traffickers: many of who operate across borders and adopt numerous aliases. Implementing a sanctions policy and operations model that is sufficiently responsive and robust to achieve compliance is no easy task.

Ignorance of the law is no excuse
For many financial institutions, complying with these sanctions regimes is a matter of legal obligation – or at the very least an issue of reputation and public relations. But the wide scope and fast-changing nature of many sanctions regimes means that compliance can only be achieved through a flexible and sophisticated approach.

Nevertheless the world’s regulators are increasingly unsympathetic to financial institutions that are unable or unwilling to meet their obligations. A number of major European banks are, or have recently been, the subject of regulatory investigation and fines. Penalties for some institutions have reached tens of millions of pounds.

A breadth and depth of expertise
Our teams of professionals are drawn from the fields of data handling and analysis, audit, regulatory, investigation and intelligence. They have a wealth of experience in designing, testing and critically examining financial sanctions methodologies, as well as delivering bespoke IT solutions and training.

Whether you are approaching the topic of sanctions compliance for the first time, are reviewing your systems and practices, or you are responding to a regulatory audit or investigation, we would be glad to assist you.