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This is a 4-hours introductory course on the source, relevance and application of International Sanctions program for Private Banking staff. Learn and understand how various International Sanction programs pose heighten compliance risks for the Private Banking sector. This course will also highlight the best practices used to ensure sanctions compliance and adequate risk mitigation in the Private Banking industry.

Target Audience

  • Private Banking Frontline Staff/ Relationship Managers
  • First Line of Defense Personnel
  • Private Banking Product Specialists

Recommended for: Private Banking & Wealth Management

Course Objectives

  • Understanding of various International Sanctions programs and their applicability to Private Banking.
  • Understand best practices in Private Banking sanctions compliance.
  • Understand key sanctions evasion red flags

Course Outline

General Overview of International Sanctions

Introduction to Sanctions (History, Purpose and Objectives)

  • Types of Sanctions (Embargo/ Trade, Financial, Sectoral, Targeted Sanctions)2
  • Key International Sanction Programs and Issuing Agencies (UN, EU, OFAC, UKSFI, DFAT, MAS, PBOC, and MAS)
  • Types of Sanction Targets, Topics and Programs (Countries, National Security, Terrorism, Organised Crime, Corruption and Illicit Trafficking, Crypto Currencies, etc;)
  • Impact of Sanctions (Impact on targets and penalties for non-compliance)

Select applications of International Sanctions relevant to Private Banking/ Wealth

  • Extraterritoriality of International Sanction Programs
  • OFAC vs EU 50% Rule
  • Select International Sanctions programs relevant to Private Banking/ Wealth (PEP/ Corruption related sanction programs: Global Magnitsky Sanctions, sanctions against political regimes; UHNWI related sanction programs: Counter Narcotics Sanctions, Non Proliferation Sanctions, Transnational Criminal Organisations, Cyber related sanctions programs, etc;)

Sanctions Compliance in Practice

  • Know Your Customer (KYC), KYC Screening, Enhanced Customer Due Diligence,Ultimate Beneficial Ownership (UBO), Source of Wealth/ Funds (SOW/ SOF) best practices
  • Customer 360, how First Line of defense staff provide the necessary sense making input
  • Common Sanctions Red Flags specific to Private Banking/ Wealth
  • Known methods of Sanctions Evasion (Information Stripping, U-Turn Payments, Proxies & Front Companies, Concealing Identities, Trade Based Methods, Correspondent Banking, etc)
  • Breakaway Working Groups of 3-5: Identifying potential sanctions risks based on profiles of fictitious clients/persons

Applying the knowledge

  • Sanctions Case Studies (Chinpo Shipping (Non-Proliferation), HSBC (Narcotics & Organised Crime), Myanmar Sanctions (PEP), etc)
  • Breakaway Working Groups of 3-5: Identifying potential sanctions red flags on fictitious case examples
  • Recap on key International Sanctions Concepts