Key focus areas include:
➡️ Exposure: Firms must take robust steps to ensure they understand relevant sanctions risks by engaging with OFSI’s guidance or seeking professional advice, particularly where parent companies have subsidiaries in high risk jurisdictions;
➡️ Adherence to policy: While policies and procedures play a key role in mitigating risk, it is essential that staff at all levels consistently follow due process to ensure they are implemented effectively; and
➡️ Ownership and control: Firms should carefully assess the ownership and control structures of entities to determine the potential applicability of sanctions.
✅ Sanctions officers should incorporate the key lessons from the announcement into their sanctions control frameworks to strengthen compliance and reduce the risk of similar breaches.
Sanctions
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