We know how important it is to stay on top of changing climates. Here’s a resource we believe will be helpful to compliance professionals by centralizing sanctions information, providing red flags around sanctions avoidance, and giving additional guidance on using resources.

There are two main types of sanctions — comprehensive and selective. Comprehensive sanctions are broad-based trade restrictions intended to stifle a country. Selective sanctions are aimed at specific entities. Both types are being applied to Russia in hopes of slowing or stopping the aggression towards Ukraine. They come in many forms and have alternatives.

SWIFT

SWIFT is a communication network that helps banks settle transactions. Network bans were a considerable escalation, but there were a couple of recurring themes that caused initial hesitation:

• Jamie Dimon suggests that a ban from a communications network isn’t actually a sanction.
• A LinkedIn excerpt from The Economist notes that a full-fledged SWIFT ban could push countries to other networks.

US Sanctions

Office of Foreign Assets Control (OFAC) homepage.

• OFAC search tool: If you don’t have an integrated sanctions search, you can use this. Based on my experience searches below a setting of 90 on the Minimum Name Scoring feature become exceedingly inaccurate, but set it at your firm’s discretion. (My name has a hit to a branch of Syrian Intelligence at a score of 81)
• Determining an OFAC match: use this to understand when you have a match and how to report it.
• Ukraine/Russia page: this is a page dedicated to Ukraine/Russian-related sanctions.

Department of Commerce “Lists of Concern”: think of these as a precursor to OFAC sanctions.

FinCEN

Red flags regarding sanctions avoidance and how to report them, provided by the Financial Crimes Enforcement Network.

ACAMS

Devoted sanctions page from the Association for Certified Anti-Money Laundering Specialists which houses educational materials and podcasts specific to sanctions.

Other Sanctions Lists

Going beyond the normal sanctions lists can reveal more risk. This helps to understand your overall exposure to international money movements, but it’s also a tradeoff between focusing on what matters to your company and understanding international exposure. Here is a list of sanctions tools outside of OFAC:

• UNSC’s search tool (open the “advanced features”)
• UK’s search tool
• EU’s search tool
• Switzerland’s search tool
• Canada’s search tool
• Australia’s searchable XLS file