Agenda
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Day 1
December 4, 2024
Networking Breakfast and Registration
SPECIAL POST-ELECTION SESSION
Preparing for the Post-Election Aftermath: Repositioning Your Economic Sanctions and Export Compliance Programs to Prepare for a New Administration
Sahand BoorboorGlobal Head of Financial Crimes ComplianceCitadel Securities
Edward FishmanSenior Research Scholar and Adjunct Professor of International and Public AffairsColumbia UniversityFormer Russia and Europe Sanctions Lead, U.S. Department of State
George IoannidisActing Deputy Special Agent in ChargeHomeland Security Investigations
Elizabeth RosenbergManaging Director, Global Financial Crimes Public PolicyBank of America
David H. LimPartnerWhite & Case LLPFormer Co-Director, Task Force KleptoCapture
Join us for a special opening panel discussion focused on the outlook of sanctions and export controls on the heels of the 2024 U.S. Presidential election. As a new administration takes office in January, organizations must be ready to proactively reposition their sanctions programs to anticipate potential changes in policies and enforcement priorities, ensuring readiness for any scenario.
During this session, we will explore the future of sanctions and what a new administration means for economic sanctions, including:
- Anticipated policy and enforcement shifts, and the impact on your organization’s risk profile
- Unpacking various scenarios that could arise from potential shifts in sanctions focus
- Creating contingency plans to address anticipated changes effectively
- Leveraging sophisticated compliance tools and technologies for real-time monitoring, automated screening, and enhanced response capabilities to swiftly adapt to new sanctions designations and real-time regulatory changes
- Strengthening risk mitigation tactics and resilience in the face of geopolitical uncertainty—impacts of a new administration
- Managing sanctions hot spots in 2025 and beyond
RUSSIA-RELATED SANCTIONS PART 1
Managing Third-Party Risk and Detangling Ownership Structures: Mitigating Secondary Sanctions Risks and Clarifying Requirements Under EO 14114
Rachel FiorillPartnerMorrison & Foerster LLP
Richard McDermottGlobal Sanctions Program DirectorAmTrust Financial Services, Inc.
Phillip ByrnesGlobal Deputy Head, Sanctions
& Global Head, Sanctions Advisory,
Financial Crime ComplianceStandard Chartered Bank
Alex BerkeHead of Defense & IntelligenceSayari
Executive Order (EO) 14114 highlights the critical need for companies to manage third-party risks and detangle complex ownership structures to avoid secondary sanctions. In today’s interconnected global economy, hidden ties to sanctioned individuals or entities can expose businesses to significant risks. EO 14114 mandates that organizations enhance their compliance programs, conduct thorough due diligence, and ensure transparency in ownership to navigate these challenges and avoid inadvertent violations.
During this panel, we will explore:
- Implementing comprehensive due diligence procedures to assess third-party relationships, including in-depth checks on ownership structures and connections to sanctioned entities
- Establishing a system for ongoing monitoring of third-party ownership and control changes to quickly identify and address any emerging sanctions risks
- Revising sanctions compliance policies to reflect EO 14114 requirements, ensuring they are communicated across your organization and to relevant third parties
- Including specific clauses in contracts with third parties that mandate compliance with EO 14114 and allowing for termination in case of violations
Networking Break
Jenn CoxSenior Manager, Trade ScreeningMicrosoft
Sara DonovanHead of Sanctions ComplianceMorgan Stanley
Luis DuarteFormer Senior OfficerOFAC
Nathan HarschVice President and Chief Compliance OfficerWestinghouse Electric Company LLC
AI may offer a transformative approach to sanctions compliance by strengthening customer due diligence and reducing false positives.
By leveraging advanced machine learning algorithms and natural language processing, organizations can analyze vast amounts of data with greater accuracy and speed than traditional methods. This could result in, enhanced identification of sanctioned entities and activities, and more efficiency and effectiveness of compliance programs.
During this panel, we will explore the lengths and limits of AI, including key issues:
- To what extent AI can enhance accuracy, efficiency, and adaptability in a complex landscape of multijurisdictional regulatory requirements
- Leveraging AI to reduce false positives
- Strengthening Customer Due Diligence through your AI toolkit
- How organizations are using advanced AI technologies to analyze and process large datasets
- Leveraging automation capabilities of GenAI to streamline the compliance process
- Dissecting the lengths and limits of AI capabilities—and when other technologies and/or manual reviews still remain key
Networking Luncheon
Managing the Convergence of Economic Sanctions, Export Controls and AML Amid Intensifying Enforcement
Justyna GudzowskaSenior Policy & Development AdvisorThe Sentry
Michael P. GradyChief, Bank Integrity Unit
Money Laundering & Asset Recovery SectionU.S. Department of Justice, Criminal Division
Ian C. RichardsonChief Counsel for Corporate Enforcement, National Security DivisionU.S. Department of Justice
Ilya ShulmanExecutive Director, Global Financial Crimes Counsel, Head of Sanctions LegalJPMorgan Chase & Co.
Andrew C. AdamsPartnerSteptoe LLP
Former Director, Task Force KleptoCapture
U.S. Department of Justice
The evolving interplay between U.S. economic sanctions, export controls, and AML is becoming increasingly complex amid heighted enforcement risks. The continued convergence of sanctions, export controls, and AML requires companies and financial institutions to implement comprehensive risk management practices and upgraded compliance strategies.
During this panel, we will explore:
- How, and why, we are seeing an increased convergence of sanctions, export controls and AML-and what this means for risk and compliance moving forward
- How sanctions, export and AML enforcement agencies are coordinating efforts-and when one enforcement action can lead to more
- Developing and implementing robust compliance strategies that integrate economic sanctions, export controls, and AML
- Leveraging existing resources to maximize compliance in each area
- Conducting regular risk assessments to identify and mitigate increasing risks associated with the evolving interplay of sanctions, export controls, and AML
Networking Break
IRAN-RELATED SANCTIONS
Transshipment and Supply Chain Security: Compliance and Consequences for Contributing to Iran and Russia’s UAV Programs
Brad Brooks-RubinPartnerArktouros PLLC
Kuang ChiangCounselA&O Shearman
Transshipment and supply chain security have become critical concerns, especially regarding the enforcement of sanctions and export controls related to Iran and Russia’s unmanned aerial vehicle (UAV) programs. The proliferation of UAVs has heightened global security risks, and the international community, particularly the U.S., has taken steps to curb the involvement of any entities that contribute to these programs.
During this panel, we will explore:
- Exploring U.S. secondary sanctions with respect to Iran
- Monitoring high-risk transshipment hubs and applying extra scrutiny to prevent diversion and sanctioned destinations
- Integrating geo-fencing capabilities in logistics systems to flag or block shipments destined for high-risk regions associated with sanctions violations
- Ensuring your ERP/trade management systems are integrated with updated global sanctions databases, enabling immediate alerts for any potential violations
- Identifying and controlling the export of dual-use items
SMALLER-GROUP ROUNDTABLES
Roundtable #4: FinTech and the Future of Sanctions
How Fintechs and Banks are Strengthening Sanctions Compliance and the Challenges They Face
David Y. LeeGlobal Director for Sanctions & Screening and OFAC OfficerPayoneerFormer Deputy Political Counselor, Head of Strategic Affairs & Sanctions Director,
U.S. Mission to the United Nations (USUN)
Andrew JensenManaging Director, Global Head of Sanctions & ABCTD
Day 1 Concludes to Networking Cocktail Reception
Day 2
December 5, 2024
Networking Breakfast and Registration
CHINA - PART I: COMPLEX DILEMMAS
Navigating the Newest, Most Complex Dilemmas Related to China: Circumvention, Expanded U.S. Export Controls and Chinese Countermeasures
Chanhee HanSenior Director, Legal Counsel, International Trade and SanctionsThe Coca-Cola Company
Bing XuChief Counsel, Global Trade Controls, Regional Head of Sanctions and Export Control – North America and Asia-PacificRolls-Royce
Andrew JensenManaging Director, Global Head of Sanctions & ABCTD
Examining strengthened U.S. export controls and sanctions Against China
- Identifying common methods used to circumvent G7 sanctions, including third-party transactions and shell companies
- Coordinated efforts among G7 countries and other allies to ensure consistent application and to close loopholes exploited by evasion strategies
- Addressing the U.S.-China technological “decoupling”
Networking Break
RUSSIA-RELATED SANCTIONS; PART 2
Navigating the Blocking of the National Settlement Depository (NSD): What it Means for Organizations Operationally
Madina IsrailovaDirector, Sanctions ComplianceUBS
Brandon SmithDirector, Americas Head of Sanctions and Anti-Bribery Corruption (ABC)Barclays
Jason PrincePartnerAkin Gump Strauss Hauer & Feld LLPImmediate-Past OFAC Chief Counsel
Navigating the blocking of Russia’s National Settlement Depository (NSD) under Russia-related sanctions poses significant operational challenges for organizations, particularly those involved in financial markets, investment, and trade with Russian entities. The NSD is a key component of Russia’s financial infrastructure, acting as the central securities depository for Russian bonds, equities, and other financial instruments. When sanctioned, the operational impact on organizations can be profound, requiring careful navigation and strategic adjustments.
During this panel, we will explore:
- Conducting a comprehensive review of your organization’s exposure to Russian securities held via the NSD and reallocating assets to non-Russian custodians to mitigate the risk of asset freezes
- Identifying and establishing alternative clearing and settlement arrangements outside of the NSD to ensure continuity in trade execution and settlement processes
- Updating your sanctions compliance program to include rigorous screening of all transactions and counterparties for ties to the NSD
- Continuously tracking and adapting to evolving sanctions regulations related to Russia
Networking Luncheon
Strengthening Your Risk-Based Approach to Sanctions Evasion: Strategies for Identifying and Combatting the Newest, Most Complex Schemes
Tara La MorteChief, Illicit Finance & Money Laundering Unit
Asset Forfeiture Coordinator
U.S. Attorney’s OfficeSouthern District of New York
Molly MoeserChief, Money Laundering and Asset Recovery SectionU.S. Department of Justice
Bahman FarahdelGlobal Head of Sanctions & Trade ComplianceBloomberg
Stephanie Brown CrippsPartnerFreshfields Bruckhaus Deringer LLP
Responding to Concurrent Sanctions and Export Enforcement Actions, Including Best Practices for Voluntary Self-Disclosures
Claire AxinnDirector, Sanctions and Risk AdvisoryCapital OneWSN Member
Dan ClutchDeputy Director, Office of Export Enforcement (OEE)
Bureau of Industry and Security (BIS)U.S. Department of Commerce
Sara NordinPartner (Brussels, Stockholm)White & Case LLP
In an increasingly complex regulatory environment, organizations face the dual challenge of navigating concurrent sanctions and export enforcement actions while ensuring compliance with evolving laws and regulations. The interplay between these enforcement areas requires a nuanced approach, particularly when it comes to voluntary self-disclosures. During this panel, we will explore:
- Implementing robust internal monitoring systems to detect potential violations
- Creating a clear protocol for voluntary self-disclosures, including guidelines on when and how to report violations, key personnel responsible for disclosures, and required documentation
- Conducting thorough internal investigations and reporting
- Investing in continuous training programs to ensure employees are aware of the latest regulatory requirements and equipped to handle compliance challenges effectively
- Determining when to disclose an actual or suspected violation
- Engaging with enforcement authorities: Concrete examples of effective cooperation
CHINA; PART 2
Conducting Detailed Risk Assessments Related to Your Operations and Business in China: revisiting Investments, Supply Chain Dependency, and Identifying Areas for Strategic Adjustments
Clay StevensonManaging Director, Global Head of Sanctions & EmbargoesDeutsche Bank
Laurence HullSenior Counsel, Global Trade - Legal and ComplianceApplied Materials
Darshak DholakiaPartnerDechert LLP
Conducting detailed risk assessments to evaluate potential exposure to China-related investments is essential for organizations to identify vulnerabilities and make strategic adjustments that safeguard their interests in an increasingly complex global environment. During this panel, we will explore:
- Creating a comprehensive map of all investments, supply chains, and partnerships tied to China to identify potential vulnerabilities
- Re-assessing investment-related risks and potential exposure
- Revisiting supply chain risks and structure
- Overcoming challenges to reducing dependency on China: Diversifying suppliers and production facilities across multiple regions to mitigate disruption risks
- Enhancing compliance protocols to ensure alignment with both Chinese regulations and international sanctions
- Adjusting your investment portfolio by reallocating assets away from high-risk sectors in China to more stable markets
Networking Break
Keeping Up with New U.S. Sanctions Designations and Delistings: How to Know If Your Program is Adapting and Integrating Rapid Changes
Aydin M. AkgünDirector of Licensing & Compliance Ferrari & AssociatesFormer Chief, Licensing Division, OFAC
Heather JacobsonDeputy Director, Office of Economic Sanctions Policy and ImplementationBureau of Economic and Business Affairs, U.S. Department of State
Omar AL-MogahedSenior Sanctions InvestigatorRobinhood
Nathanael KurcabOf CounselMorrison & Foerster LLP
As OFAC regularly updates its list of sanctioned entities and individuals, the implications for businesses can be significant, affecting everything from supply chains to financial transactions. Navigating these changes requires a nuanced understanding of the regulations and a proactive approach to compliance, ensuring that your organization can adapt swiftly and effectively to maintain legal standing, avoid penalties, and continue smooth operations. During this panel, we will explore:
- Implementing automated systems to receive instant notifications about new OFAC sanctions designations and delistings to stay informed of regulatory changes in real-time
- Creating and maintain a contingency plan for rapid response to unexpected changes in OFAC sanctions, including protocols for handling immediate compliance issues
- Navigating OFAC’s new “unblocking reporting”
- Utilizing advanced data analytics and machine learning tools to enhance the detection and monitoring of transactions and relationships that may involve newly sanctioned entities
Human Rights and Forced Labor: Incorporating UFLPA, Global Magnitsky and Targeted Sanctions into Your Compliance Strategy
Adam M. SmithPartnerGibson, Dunn & Crutcher LLP
Philip SmithGroup Head of Financial Crime Risk ManagementBooking Holdings
The Global Magnitsky Act imposes sanctions on individuals and entities involved in serious human rights abuses and corruption worldwide, while the Uyghur Forced Labor Prevention Act (UFLPA) targets entities implicated in forced labor practices within China’s Xinjiang region. During this panel, we will explore key issues, including:
- Performing thorough audits to identify and address any links to forced labor in Xinjiang and ensuring transparency in your supply chains
- Adjusting your compliance programs to incorporate the Global Magnitsky Act and the Uyghur Forced Labor Prevention Act
- Implementing systems for real-time monitoring of new Global Magnitsky designations and UFLPA-related updates to ensure ongoing compliance
- Leveraging advanced technologies to improve supply chain traceability and verify that products are not associated with forced labor practices