The publication aims to assist stakeholders in understanding and protecting against threats to compliance following the extension of reporting requirements to AMPs and HVDs earlier this year.
Key judgements from the assessment include:
➡️ It is highly likely that high-value goods owned by designated persons (DPs) in the UK have not been reported to OFSI; and
➡️ It is likely that Russian DPs and enablers have breached asset freezing prohibitions in the UK by dealing with high-value goods.
✅ AMPs and HVDs should review their sanctions risk assessments to ensure the inherent risk posed by DPs is appropriately identified and addressed by control frameworks.
💡 Plenitude’s Advisory & Transformation Service conducts Business-Wide Risk Assessments, helping clients to assess their inherent and residual financial crime risks. Visit our website for more information: https://www.plenitudeconsulting.com/services/advisory-and-transformation