Sanctions Policy & Manual (2026)

Sanctions Policy & Manual (2026)

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

This Sanctions Policy and Manual establishes a comprehensive framework for ensuring the Company’s full compliance with international, European Union, and national sanctions regimes. It sets out the principles, governance arrangements, policies, procedures, systems, and controls designed to prevent, detect, and manage sanctions risks arising from the Company’s business activities, client relationships, and transactions. The Manual reflects a zero-tolerance approach to sanctions violations and emphasizes that sanctions compliance is a critical component of the Company’s overall risk management and regulatory compliance framework.

The Manual is grounded in the applicable legal and regulatory framework, including United Nations Security Council sanctions, EU restrictive measures, and the Cyprus national sanctions regime. Particular emphasis is placed on the Criminalization of the Violation of EU Restrictive Measures Law of 2025 and the establishment of the National Sanctions Implementation Unit, which significantly strengthen enforcement, reporting obligations, and penalties. The Manual clearly outlines the severe criminal, administrative, and reputational consequences of non-compliance, highlighting the strict-liability nature of sanctions and the obligation to act immediately once a person, entity, transaction, or activity becomes subject to sanctions.

At its core, the Manual defines the Company’s Sanctions Compliance Program (SCP), which is built on a proportionate and risk-based approach. The SCP is structured around key pillars, including senior management and Board oversight, a documented sanctions risk assessment, robust policies and procedures, effective screening of clients and transactions, clear reporting and escalation mechanisms, ongoing training and awareness, record-keeping, and independent testing and auditing. Senior management bears ultimate responsibility for the effectiveness of the SCP and for fostering a strong culture of compliance across the organization.

The Manual provides a detailed explanation of the different categories of sanctions - comprehensive, regime-based, sectoral, and list-based - and explains how multiple sanctions regimes may apply concurrently to a single business relationship or transaction. It also addresses financial sanctions, including asset freezes and prohibitions on making funds or economic resources available to designated persons, as well as sector-specific restrictions such as those affecting energy, trade, transport, and maritime activities. Guidance is included on derogations, exemptions, and licensing requirements, emphasizing that any authorization granted is strictly limited in scope and conditions.

A significant focus of the Manual is the identification and mitigation of sanctions circumvention risks. It describes common evasion techniques used by designated persons and their enablers, outlines relevant red flags and typologies, and stresses the importance of enhanced due diligence, ongoing monitoring, and staff vigilance. The roles and responsibilities of the Compliance Officer are clearly defined, including oversight of sanctions screening, investigation of potential matches, reporting to competent authorities, staff training, and regular review and updating of the Sanctions Policy and Manual.

Overall, the Sanctions Policy and Manual serves as the authoritative reference document for sanctions compliance within the Company. It aims to ensure that the Company conducts its business lawfully, ethically, and responsibly, protects its reputation, and contributes to the broader objectives of international peace, security, and the rule of law by preventing involvement in sanctioned activities or relationship.

Areas Covered

Our comprehensive template covers the following areas:

• Relevant Legislation
• Sanctions Policy
• Categories of Sanctions
• Overview of the Sanctions Manual
  • 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 Circumvention
• 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
• Specific Prohibitions & Restrictions
• Freezing and Unfreezing accounts Subject to Sanctions
• Assessment of whether a client is affected by sanctions
• Indicators / Red Flags
• Maintaining effective and efficient Sanctions Screening Systems

What is included?

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