Best Practice Tips from ACI’s Economic Sanctions Enforcement & Compliance Speaker: David Nance

Head of Sanctions Compliance

ING (The Netherlands)

Implement a general sanctions compliance training program for your entire organization. It doesn’t have to be anything complicated – a fairly short, fairly general presentation or e-learning will do. When ING required all staff to take a sanctions e-learning, we were struck by how interested everybody – and not just compliance – was in the topic, and how engaged people were. As a consequence, the level of awareness of sanctions issues now is very high, and it makes it much easier to explain to people why we’re doing what we’re doing.

Understand the mechanics of the business. This may sound obvious, but there is often a real gap between compliance and the business, and compliance doesn’t always understand what the business does, how it does it, or what incentives it is responding to. Understanding of the business should extend into the mechanics; for example, for a bank, what the deal flow looks like. This also extends to even very technical details, such as understanding what goes into each field of a Swift message or the documents involved in a letter of credit transaction. It may seem trivial, but at least one bank has been fined by OFAC because no one understood the contents of a payment message that referenced an Iranian party.

When: Wednesday, April 30 to Thursday, May 01, 2014

Where: Westin Georgetown, Washington, DC