Sanctions Compliance Training for Employees

Section 1: Overview of Sanctions and Embargoes

This section introduces learners to the global sanctions landscape, covering the basics of what sanctions and embargoes are, and their implications for businesses. Learners will explore the different types of sanctions, including comprehensive, targeted, and arms embargoes, and the global regulators that enforce these laws, such as OFAC, UN, EU, and FATF. Real-world case studies are used to highlight the severe consequences of non-compliance, such as fines and blocked accounts. This section emphasizes why businesses must comply with sanctions, even if they are not directly listed in the laws. Key Topics Covered:

• Definitions of sanctions and embargoes
• Types of sanctions: comprehensive, targeted, and arms embargoes
• Key enforcement bodies: OFAC, UN, EU, FATF
• Consequences of non-compliance: fines and penalties
• Real-world examples of sanctions violations

Section 2: How to Comply with Sanctions

In this section, learners will gain practical knowledge on how to comply with sanctions. This includes understanding and conducting sanctions screening for customers, vendors, payments, and cargo. The module also covers the use of watchlists (e.g., OFAC SDN list) and the importance of conducting thorough due diligence. Learners will explore the risks posed by third-party intermediaries and how to spot red flags like sudden changes in ownership or vague delivery addresses. Key Topics Covered:

• Sanctions screening processes for various transactions
• Understanding and using sanctions watchlists
• Due diligence: verifying identities and ownership structures
• Risks of third-party transactions and intermediaries
• Identifying and addressing red flags (e.g., unusual ownership changes)

Section 3: Your Responsibilities and Reporting Concerns

Sanctions compliance is a shared responsibility across the organization. This section outlines the role each employee plays in recognizing and reporting suspicious activities related to sanctions violations. Learners will understand when to raise a red flag, whom to report concerns to internally, and how to protect their confidentiality through whistleblower protections. The module stresses the importance of following company procedures and maintaining documentation for compliance purposes. Key Topics Covered:

• Identifying when to raise a red flag
• Whom to contact: internal reporting channels
• Confidentiality and non-retaliation protections for reporters
• The importance of compliance and documentation
• What not to do: approve transactions under pressure

Section 4: Summary and Assessment

This section recaps the key lessons from the course, reinforcing the importance of understanding sanctions and embargoes, and recognizing risky interactions. Learners will complete a short assessment to test their knowledge and ensure they can apply what they’ve learned. A Certificate of Completion will be issued upon successful completion, which can be used for audit purposes and HR documentation. Key Topics Covered:

• Key takeaways on sanctions and embargoes
• Recap of compliance actions and employee responsibilities
• Final assessment and certification