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A PEP extends to the immediate family


Taking this problem and finding a solution that supports the business in achieving its goals, while still managing the overall risk that you face, makes you a super-hero rather than the arch-enemy!


members as well, so even if a politician from an unpleasant regime has distanced themself from the business activity, we should be able to spot it. In the UK, sanctions are handled by the


Office of Financial Sanctions Implementation, part of HM Treasury. At the time of writing, there were 25 regimes on their list. But we are not done yet. There are 34 regimes listed on the EU’s


Restrictive Measures Sanctions List and yes, Brexit or no Brexit, we have to be compliant with them for at least the next four years. But we are not done yet. In the USA, the


your vendors too, to ensure that your whole supply-chain is clean. What should we be screening for? Well, typically you should be screening for these categories: l Politically exposed persons (PEP). l Sanctions. l Financial regulatory. l Law enforcement. l Disqualified directors. l Insolvency. l Adverse media. You need to screen for PEPs as you may


find that a director of your customer is involved, in some way, with a government with whom we should not be dealing, for sanctions or money-laundering reasons.


December 2017


Office of Foreign Assets Control maintains a list of Specially Designated Nationals and there are 33 individual sanctions programmes; the US State Department’s Bureau of International Security & Non-Proliferation Sanctions maintains their own Terrorist Exclusion List and Non-Proliferation Sanctions List on Missile, Executive Orders, Iran North Korea & Syria, Chemical & Biological Weapons, Nuclear Proliferation, Export-Import Bank Act and the Transfer of Lethal Military Equipment. But we are not done yet. There are 17


United Nations Security Council Resolutions to take into account and another 91 unilateral sanctions and regulatory enforcement lists. Ok, now we are done! Given the serious consequences of getting it wrong, it is clear to me that we should not


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try to review every customer or supplier, new or old, on our own, by physically checking each of the over 150 lists. It would be an impossible task and end up consuming all of your resources. Fortunately for us, there are partners out there who can help us with this screening exercise and it does not need to cost the earth. We have been able to move from a non-


compliant to a compliant status in just a few months, and we are now introducing that to all of the other businesses in our group. There is a tendency, as compliance is often


seen as a legal matter, for this process to be run by your legal team. I would counsel against that: find a


partner to work with and grasp the nettle yourself – you will shave months off the whole process and it will also make you the expert on this matter, which can only improve your working relationship with the commercial team. This brings me back to my initial point of


knowing yourself: taking this problem and finding a solution that supports the business in achieving its goals, while still managing the overall risk that you face, makes you a super-hero rather than the arch-enemy! This is a big subject that can get quite


scary and I have not been able to cover it all in this piece. So, if you would like to find out more before getting measured up for your spandex suit and cape, just drop me a line! CCR2


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