Global Sanctions Compliance

In 2019, the US Treasury Department issued detailed guidance setting expectations for an adequate Sanctions Compliance Program (SCP):

• Management commitment: Senior management must delegate sufficient authority and provide adequate resources to the compliance function to execute the program as designed.
• Risk assessment: The SCP should include a “holistic review” of the global organization to identify the scope and nature of its interactions with external entities.
• Internal controls: The SCP should include internal controls such as policies, procedures, regular audits, and adequate recordkeeping.
• Testing and auditing: The SCP should be tested by an audit function that is directly accountable to senior management, independent of the function being reviewed, and technically qualified to review the activities in its audit scope.
• Training: The SCP should be communicated via a broadly accessible global training program that communicates job-specific sanction compliance responsibilities and evaluates compliance awareness.

Our Experts

BRG professionals are industry leaders in addressing the full range of sanctions compliance challenges to both prevent and respond to potential violations. They bring decades of experience as in-house compliance professionals, former senior regulators and law enforcement professionals, internal auditors, and technology specialists.

Our Services

BRG’s Sanctions Risk Management Services include:

Proactive Compliance

• Global sanctions enterprise risk assessment and modeling
• SCP assessment and operational design
• Sanctions compliance data rationalization and enhancement
• Sanctions compliance technology consulting and implementation
• Transaction risk model design
• Global enhanced due diligence (EDD) support
• Internal compliance audit co-sourcing
• Global compliance training design and delivery

Incident Response

• Internal investigation/look-back exercises
• Program remediation
• Post-settlement compliance monitorships
• De-listing petitions