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Amid the £231 Million Lloyds TSB Penalty and Widening OFAC Investigations Across Europe, Can your Sanctions Compliance Programme Sustain the Heat of an Enforcement Action?
Now more than ever, economic sanctions pose unprecedented compliance risks for financial institutions and global companies in Europe. Lloyds TSB recently agreed to pay a £231 million penalty, the largest fine ever imposed for violations of US sanctions regulations. The probe is widening and the investigation has reportedly expanded to nine European banks. US enforcement actions affect companies and banks with a presence in the United States but also those that engage in transactions using US dollars or involving US banks. These actions further demonstrate the extraterritorial reach of US laws and regulations, which can carry significant monetary penalties and reputational damage for non-US companies and financial institutions. Companies in Europe must institute preventative measures and reassess their existing compliance efforts to ensure their adequacy under the increased climate of risk. Failure to detect and prevent sanctions breaches is otherwise likely to result in staggering penalties and reputational damage. After the success of their inaugural conference in London, American Conference Institute and C5 Group are pleased to introduce the 2nd European Forum on Economic Sanctions, Frankfurt edition. A stellar faculty of senior government officials, industry leaders and seasoned attorneys will provide the latest insights on:
- How OFAC regulates the activities of parties in the global payment process
- Investigating potential sanctions breaches and managing restrictions from regional banking secrecy, data protection and privacy laws
- What is – and isn’t considered facilitation
- European economic sanctions update: regulatory and enforcement initiatives impacting your operations
- Preventing sanctions breaches in international transactions and underwritings
- Addressing directly opposing sanctions regimes
Contents & Contributors
The Extraterritorial Reach of US Sanctions: How OFAC Rules Apply to Non-US Entities and Activities
Greta Lichtenbaum, O’Melveny & Myers LLP (Washington)
Widening OFAC Investigation of European Entities: The Aftermath of Lloyds TSB Penalty and How to Prepare
John B. Reynolds, Wiley Rein LLP (Washington)
Complying with Tightened Iran Sanctions: What You Can and Can’t Do
David Barry, EMEA Trade Compliance Manager, Honeywell (Dublin)
Sunwinder Mann, Baker and McKenzie LLP (London)
Eva Rehberg, Parter, Customs & International Trade, Deloitte Accountants BV (Germany)
SWIFT Wire Transfer Transparency Initiatives: New Standards and Their Requirements
Nicolas Stuckens, Marketing Manager, AML & Sanctions| Banks and Payments, Market Infrastructures, SWIFT (London)
Implementing a Robust Screening Programme to Meet US and EU Prohibitions and Requirements
Tom Scampion, Partner, Enterprise Risk Services, Deloitte LLP (London)
Peter Green , Chief Money Laundering Reporting, BNP Paribas (Paris)
Peter Klein, Head of Export and Trade Controls, Airbus (Toulouse)
Investigating Potential Sanctions Breaches: How to Access Information and Comply with Data Protection and Privacy Laws
Martial Smets, Chief Compliance Officer , GE Global Banking (Prague)
Joseph P. Armao, Linklaters LLP (New York)
The Facilitation Prohibition: What It Is and How to Minimize Risks
Wolter Boerman, Vice President, Corporate Export Controls & Supply Chain, Security , Philips International (Eindhoven)
William B. Hoffman , Davis Polk & Wardwell (Washington)
Developing a Risk-Based Compliance Programme, from the Ground Up: Core Components and How to Promote Awareness
Laurent Claassen, Partner, Deloitte Enterprise Risk Services/Financial Services Industry, Deloitte Accountants BV (Amstelveen, The Netherlands)
Tassilo W. Amtage, Head of Foreign Trade & Sanctions, Commerzbank AG (Frankfurt)
Markus E. Schulz, Chief Compliance Officer Global Life & Banking, Group, Financial Crime Officer, Zurich Financial Services (Zurich)
Jens Burgard, Senior Corporate Counsel, Siemens AG (Frankfurt)
Update on European Economic Sanctions: Regulatory and Enforcement Initiatives Impacting Your Operations
Richard Reimer, Lovells LLP (Frankfurt)
Preventing Sanctions Breaches in International Transactions and Underwritings
Mark Anderson, Head of AML Compliance, EMEA, UBS Investment Bank (London)
Stefan Heinisch, Senior Legal Counsel, Group Legal Services – Compliance, Hannover Re (Hannover)
Dale C. Turza, Cadwalader, Wickersham & Taft LLP (Washington)
Reconciling Conflicts of Law Between US and EU Sanctions Regimes and Blocking Measures
Stephan Müller, Oppenhoff & Partner Rechtsanwalte (Frankfurt)
Publication Details