CRYPTOCURRENCY AWARENESS

How to Update Your Sanctions Compliance Program

December 6, 2018 3:15pm

Ann Broeker
Senior Compliance Counsel
Visa (Washington, DC)

Jonathan Thomas
Co-Head Government Sanctions Group
Goldman Sachs (New York, NY)

Gary Stein
Partner
Schulte Roth & Zabel LLP (New York, NY)

  • Clarification of what could be a sanctions evasion from cryptocurrency
  • How to meet regulators requirements for “reasonable and proportionate”
  • Protocol to identify possible high risk customers or third parties
  • Specific internal procedures to add to your sanctions compliance program