Sanctions Compliance program

Sanctions Compliance program

Description

Our Sanctions Compliance Program (SCP) is designed for regulated entities, however it is suitable for any type of business. It can be customised by following the instructions in the enclosed “Terms of Use-Customisation Instructions” document.

Overview

As per the Directive for compliance with the provisions of UN Security Council Resolutions (Sanctions) and the Decisions/Regulations of the Council of the European Union (Restrictive Measures), a sanctions compliance program should be developed and implemented by all ICPAC members. The sanctions compliance program should be appropriate, adequate, proportionate to firm’s nature and size and effective in order to manage and mitigate the sanctions risks faced by the firm.

An appropriate sanctions compliance program should include, as a minimum, the following:

• The establishment of a sanctions risk assessment
• The development of policies, procedures, systems, and controls
• Screening processes
• Reporting matches and breaches of the sanctions’ regime
• Training and awareness
• Record keeping

Areas Covered

Our comprehensive template covers the following areas:

• Overview of the Sanctions Compliance Program
  • Description of sanctions
  • Ensure compliance with sanctions
  • Proportionate and risk-based Sanctions compliance programme
  • Preventive measures
  • Mitigating measures on sanctions risk
  • Responsibilities of the Compliance Officer
• Sanctions Compliance Program
  • Senior Management commitment
  • Sanctions Risk assessment
  • Policies, Procedures, Systems and Controls
  • Sanctions screening
  • Reporting obligations
  • Training and awareness
  • Record keeping
  • Testing and auditing
• Assessment of whether a client is affected by sanctions
• Indicators

What is included?

• 46-page Sanctions Compliance Program Template
• Terms of Use-Customisation Instructions