When actual or suspected sanctions violations arise, organizations must quickly assess exposure, determine enforcement risk, and decide how best to respond under increasing regulatory scrutiny. This advanced, scenario-based workshop will provide a practical framework for managing sanctions matters from initial identification through investigation, remediation, and voluntary self-disclosure decision-making.

Participants will examine complex cases involving beneficial ownership structures, third-party intermediaries, cross-border transactions, sanctions evasion indicators, and multi-jurisdictional compliance challenges. Through detailed case studies and interactive discussions, attendees will develop strategies for conducting defensible investigations, assessing materiality, engaging stakeholders, managing regulator expectations, and demonstrating an effective culture of compliance while minimizing legal, operational, and reputational risk.

Key Learning Objectives:

• Defining investigation scope in matters involving complex ownership structures, indirect dealings, third-party intermediaries, and potential sanctions evasion
• Conducting transactional lookbacks, root-cause analyses, and exposure assessments to determine the extent and impact of potential violations
• Applying risk-based methodologies to assess materiality, enforcement exposure, aggravating and mitigating factors, and potential regulatory outcomes
• Evaluating voluntary self-disclosure considerations, disclosure timing, regulator expectations, and factors that influence penalty determinations
• Managing investigations involving legal privilege, cross-border data restrictions, competing regulatory obligations, and multiple enforcement authorities
• Developing comprehensive remediation strategies that address control weaknesses, governance failures, root-cause issues, and systemic compliance deficiencies while strengthening sanctions controls, demonstrating a culture of compliance, and reducing future regulatory and enforcement risk.
• Preparing investigation reports, decision memoranda, and supporting documentation that can withstand regulatory scrutiny and support defensible decision-making
• Applying lessons learned from recent OFAC and international enforcement actions to strengthen investigative protocols, escalation procedures, and overall sanctions compliance effectiveness