Day 1 - Wednesday, October 2, 2019

7:45
Registration and Continental Breakfast
8:45
Co-Chairs’ Opening Remarks

Jonathan Thomas
Global Head, Sanctions Group
Goldman Sachs (New York, NY)

9:00
New OFAC Compliance Expectations: Guidance on What is an Effective Sanctions Compliance Program (SCP)

Bridget Van Buren
Sanctions Compliance Officer
Office of Foreign Assets Control (OFAC), U.S. Department of the Treasury (Washington, DC)

Q&A moderated by :

Peter Flanagan

Peter L. Flanagan
Partner
Covington & Burling LLP (Washington, DC)

  • 5 Essential Components of OFAC’s Compliance Framework
  • How to make best use of key OFAC resources
  • How OFAC plans to evaluate your sanctions compliance program
  • What penalties can be expected in the event of non-compliance

9:45
In-House Views: Sanctions Compliance Best Practices from Seasoned Experts

Robert Hurst
Sr. Director, Global Sanctions Compliance
PayPal (New York, NY)

Susan Rodihan Dupuy
Managing Director, Head of Sanctions Compliance for the Americas
Société Générale (New York, NY)

Tina Shaughnessy
Director & Senior Counsel, Export/Sanctions
Varian Medical Systems (Washington, DC)

  • Highlights of effective sanctions programs
  • Challenges of keeping your program current
  • Staffing and resource allocation
  • How to implement policies globally
  • The most common pitfalls and breakdowns

10:30
Coffee & Networking Break
10:45
OFAC Guidance: Lessons Learned from Recent Enforcement Actions

Brenda Perrotti
Vice President, AML Sanctions Senior Manager
PNC (East Brunswick, NJ)

Tina Shaughnessy
Director & Senior Counsel, Export/Sanctions
Varian Medical Systems (Washington, DC)

Jonathan Thomas
Global Head, Sanctions Group
Goldman Sachs (New York, NY)

During this panel, speakers will analyze and elaborate on the most significant recent OFAC sanctions enforcement cases impacting industry. The conversation will conclude with the drawing of conclusions and summing up of best practices that can immediately be implemented by in-house compliance officers. Cases analyzed will include, among others, Systems Inc. (Ukraine), UniCredit Bank AG (Cuba), State Street (Iran), and Standard Chartered Bank (Burma, Cuba, Iran, Sudan).

11:45
Managing Your Risk Profile: Potential Sanctions Landmines to Watch Closely and Address Proactively

Guidette P. Laracuente
Vice President, Head of Policy, Communications, Advisory, and Training
Bank of China (New York, NY)

Michael Court

Michael Court
Associate General Counsel
Agricultural Bank of China (New York, NY)

  • Iran: How the EU and other countries are building sophisticated workarounds to U.S.-imposed trade restrictions and use of the U.S. dollar as main currency
  • Venezuela and Russia Sanctions Considerations
  • Shipping and Transportation Challenges
  • Potential M&A successor liability issues

12:45
Networking Lunch
2:00
Sanctions Training Programs: Duration, Frequency, Breadth and Content

Susan Rodihan Dupuy
Managing Director, Head of Sanctions Compliance for the Americas
Société Générale (New York, NY)

Robert Hurst
Sr. Director, Global Sanctions Compliance
PayPal (New York, NY)

  • What format of training is best for a global organization?
  • The importance of “marrying” in-house systems (e.g., HR and finance/employee expenses) to trigger red flags early
  • Determining the frequency of training based on job function
  • Should you use on-line testing for some or all employees?
  • How to “get your training right” and ensure continued buy-in at all levels of your organization

2:45
Focus on Audits: A More Nuanced Approach for Auditing & Testing Your Compliance Program

Stephanie Norris
ITC Manager - Screening and Contracts
General Electric (Washington, DC)

  • OFAC has raised the bar – Now, what does this mean for your compliance efforts?
  • How to pressure test your compliance program for weaknesses and inefficiencies
  • Real-world considerations for screening
  • Applying OFAC’s 50% rule in the real world

3:30
Coffee & Networking Break
3:45
“Would You Report to OFAC If…”: Real-World Hypotheticals and Audience Polling

Ted Starishevsky
Vice-President, Global Head of Sanctions & Anti-Corruption, Global Financial Crimes Compliance
American Express (New York, NY)

Guidette P. Laracuente
Vice President, Head of Policy, Communications, Advisory, and Training
Bank of China (New York, NY)

  • …a potential violation is uncovered
  • you discover that a competitor is in violation of sanctions rules?
  • …your non-US company wanted to conduct business with a U.S.-sanctioned country or entity as a non-US company with an American CEO who lives outside the U.S.?

4:30
Creating a Culture of Compliance: Proven Techniques to Ensure Senior Management Buy-In

Molly J. Miller
Senior Director, Economic Sanctions and Trade Controls
Capital One (New York, NY)

Brenda Perrotti
Vice President, AML Sanctions Senior Manager
PNC (East Brunswick, NJ)

  • Annual SCP Certification practicalities
  • Successful strategies to communicate with senior management and the board
  • Tone from the top

5:15
Think Tank Concludes