Meeting economic sanctions strategically

Transcription

1 Meeting economic sanctions strategically Our Sanctions Quick Check analysis the readiness of companies and institutes to deal with economic sanctions in a targeted way.

2 The Challenge In recent years, supervisory authorities have focused their attention on banks and financial institutions, with a particular interest in violations of financial sanctions. Sanctions programmes are becoming ever more complex and entail new risks. Companies with complex production and sales structures increasingly face the challenge of meeting sanctions compliance requirements and expectations efficiently and sustainably. In addition, companies should be aware that long term, intensive investigations of banks may draw attention to business activities they themselves were involved in. The potential liability of companies in connection with transactions affected by sanctions needs to be assessed. The requirements of regulators in the European Union and in the Anglo-Saxon region pose growing challenges for both the compliance organisation and the business units involved. If there is a US nexus, the requirements relating to US regulations must be carefully observed in order to avoid high monetary penalties. Complex sanction programmes in a constantly changing market environment mean growing demands on businesses and their business activities. Our recent study Economic Crime 2018 shows that companies need to take action in the field of Compliance Development to avoid violating international financial and economic sanctions. Only 49% of the companies surveyed have a CMS in this area, although the impact of international sanctions goes way beyond the financial sector, affecting companies in almost all industries.

3 Our Approach Our Sanctions Quick Check approach consists of three main phases Identify risk In order to avoid risks in relation to business activities that may be affected by sanctions, we analyse existing safeguards within the corporate organisation. As part of a target/ performance comparison, we highlight selected focus areas of a Sanctions Framework. Our recommendations are based on standard best practice approaches and requirements defined by regulatory authorities. Identification of issues in the Sanctions Framework makes it possible to monitor risks in a targeted way. Define potential for adjustment and expansion Based on existing safeguards and those identified as necessary, we define the potential for further adaptations and expansion. Proposed steps look to both the organistional structure and operational processes. In outlining our recommendations for required actions, we highlight quick-win measures our client companies can take. Set a framework for strategic influence factors We suggest analysing our results with you against the background of relevant factors in your corporate strategy. In this review, we also recommend using the comprehensive corporate and customer data from Compliance for generating additional business opportunities.

4 The Solution Our holistic approach helps companies to properly meet the specific individual challenges they face when dealing with economic sanctions. Sanctions Quick Check The Sanctions Quick Check supports correct assessment of the economic sanctions risk for the company as a whole as well as for existing or planned business activities. As part of this short term analysis, we provide an overview of the readiness of your company for economic sanctions. It outlines existing sanction risks and safeguards within the organisation and identifies possible factors that have an influence on corporate strategy. Fig. 1 Holistic approach Sanctions Quick Check Change the Company (incl. Quick Wins) Sanctions Framework/ Operating Model Sanctions Framework/Operating Model The Sanctions Quick Check may result in action requirements. In the interests of sustainable risk management and monitoring, we recommend as part of the implementation process that the results are included in the organisation of the company by implementing a Sanctions Framework or Operating Model that efficiently bundles competencies and activities. Uniform structures in the organisation and its processes enable fast and targeted action with regard to internal and external requirements so that opportunities are recognized and the greatest possible efficiency of work processes is achieved both in Compliance and in the operational business units.

5 The Benefits Analyse relevance: The Sanctions Quick Check enables you to quickly survey the influencing factors of economic sanctions on the company as well as already implemented risk-mitigating measures. Risk management: A Sanctions Framework or Compliance Operating Model takes account of the specific requirements of a business and serves to uniformly control internal and external requirements. Recognise opportunities: Optimising interfaces and responsibilities between Compliance and business units leads to a more efficient organisation of work processes and helps to identify new business potentials. Consistent performance: Unified structures in the organisational and operational setup facilitate speedier and targeted responses to internal and external requirements. The benefits of a compliance organisation go far beyond simply ensuring compliance with regulations. Compliance is a real value added to the overall success of a company. Companies know the complexity of their customer and supplier structure. Based Sustainable safeguards are implemented all along the value chain of client companies. on potential risk situations, a Sanctions Framework/Operating Model takes into account the specific requirements of sanction programmes. Reporting on changes and the effects of sanctions programmes supports quick risk identification limiting business activity and immediate reaction to emerging opportunities new business potentials....

6 Your Point of Contact Lars-Heiko Kruse Partner, Forensic Services Lawyer and Sanctions Leader Germany Tel: Mobile: Lothar Müller Manager, Forensic Services Tel: Mobile: Marco Smeets Senior Consultant, Forensic Services Tel: Mobile: PricewaterhouseCoopers GmbH Wirtschaftsprüfungsgesellschaft adheres to the PwC-Ethikgrundsätze/PwC Code of Conduct (available in German at and to the Ten Principles of the UN Global Compact (available in German and English at Photo: gettyimages/westend61 March 2018 PricewaterhouseCoopers GmbH Wirtschaftsprüfungsgesellschaft. All rights reserved. In this document, PwC refers to PricewaterhouseCoopers GmbH Wirtschaftsprüfungsgesellschaft, which is a member firm of PricewaterhouseCoopers International Limited (PwCIL). Each member firm of PwCIL is a separate and independent legal entity.