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Obliged Entities should design and implement measures and procedures for the detection of actions that are in breach or may potentially be in breach of the provisions of the United Nations Security Council Resolutions or Decisions (‘Sanctions’) or/and the European Union Council Decisions and Regulations (‘Restrictive Measures’), as provided for in the Sanctions Law.
Any person who violates any of the provisions of the Resolutions or Decisions of the Security Council (Sanctions) and/or the Decisions and Regulations of the Council of the European Union (Restrictive Measures), is guilty of an offence and subject to the reservation of any other legal provision establishing higher penalty, in case of conviction is subject:
A) If it is a natural person, to imprisonment not exceeding 2 years or a pecuniary penalty not exceeding €100,000 or both penalties,
B) If it is a legal person, to a pecuniary penalty not exceeding €300,000.
In line with above provision of the relevant legislation regulated entities should develop a sanctions policy outlining the principles to be followed in order to comply with the requirements of the Sanctions’ Laws and also the mitigation of risks arising from the sanctions risk assessment.
Compliance with sanctions, or restrictive measures, is important for:
- The avoidance of criminal, civil or regulatory action and/or penalties that may be taken against the Company by regulatory or other authorities,
- The protection of the Company´s reputation, and
- Cypriot national security and rule of law; the safety and security of other EU Members and countries around the world; the effort to combat terrorist financing and proliferation; and respect for civil society and human rights.
Our comprehensive template covers the following areas:
- The purpose of having a Sanction Policy.
- The General principles of the U.S., U.N. and E.U. Sanctions regimes.
- Definition and explanation of Sanctions.
- Sanctions issuing authorities.
- Description of Financial Sanctions.
- Description of Individual country Sanctions regimes.
- Description of the different categories of Sanctions.
- Analysis of Sanctions application.
- Assessment of whether a client is affected by sanctions.
- The tactics used by Designated persons to circumvent Sanctions.
- The main principles of a Sanctions Compliance Program.
- The specific prohibitions & restrictions with respect to sanctions against specific lists of named individuals, legal entities, organisations, vessels or other U.S Specially Designated Nationals or EU asset freeze targets.
- Freezing and unfreezing accounts subject to Sanctions.
- The consequences of Non-Compliance.
- The list of indicators suspected of being used to evade sanctions or otherwise hide assets.
What is included?
- 32-page Sanctions Policy Template