HGC CONSULTING PLUS

Foreword

Introduction

Chapter 1: History, Definition, and Scope of Sanctions
History of Sanctions
What Are Sanctions?
OFAC Sanctions and Their Scope
Forms of Sanctions
Humanitarian Exceptions
Applicability and Scope of OFAC Sanctions
Industries
Extraterritoriality
Definition of “Transaction”
Interpretation and Implications of the Definition of “Prohibited Transactions”
Case Study

Chapter 2: The Foundational Elements of an OFAC Sanctions Program
Senior Management Commitment and How to Obtain It
The Importance of Internal Controls
Risk Assessments as Starting Point of All Program Elements
Implementation 
Documentation/Risk Matrix Template

Chapter 3: Policies and Procedures (P&Ps)
Pros and Cons of Combination with Other Relevant Policies
Regulatory Expectations on P&Ps
Sample Policy Elements
Case Study

Chapter 4: Training
Regulatory Requirements
Sample Training Modules

Chapter 5: Testing and Auditing
The Importance of Testing and Auditing
OFAC Examination Procedures as Guidance

Chapter 6: Customer and Third-Party Due Diligence
Beneficial Ownership
Politically Exposed Persons (PEPs)
Investigation of Potential OFAC Sanctions Violations
Reduction of “False Hits”
Benefits of Consolidation of AML, Anti-Corruption, and OFAC Sanctions Programs
Importance of Having a “Seat at the Table” in M&A Transactions by Conducting OFAC