Sanctions Surveillance: 9 Crucial Steps to Help Prevent Costly Sanctions Breaches

With the ever-growing focus on ESG and increased compliance legislation across the globe, it has become even more important for business to keep up with regulation to avoid costly sanctions.

Even if your business is not violating the law directly, you can be found liable for sanctions if your third-party partners are violating the law. That's why a rigorous and continuous due diligence process is so important.

In this post, we'll go over 9 steps to make sure your due diligence is up to par so you manage your risk of sanctions or other consequences.

What are sanctions?

Sanctions involve a wide range of measures—from asset freezes to trade embargoes—to exact pressure on individuals, organizations, and nation states to meet international and national standards of conduct. What’s more, the number of sanctions regimes continues to grow, further complicating on-going risk management.

The costs of inadequate sanctions screenings are significant, including potential reputational damage, substantial fines, and exclusion from future business contracts.

Fortunately, you can mitigate your sanction risk with thorough due diligence screening.

How to create an effective sanction screening process
Keeping a constant eye on sanctions, watchlists, politically exposed persons (PEPs), and state owned enterprises (SOEs) demands a proactive approach. Here are 10 best practices to follow when implementing sanction checks:

• Take a top-down approach by building a culture of compliance from the Board and C-suite to managers and employees.
• Maintain up-to-date policies and procedures that evolve with the entire sanctions environment, from UN Security Council sanctions to those implemented by the United States
• Clearly communicate these policies and procedures to employees and any third parties operating on behalf of your organization.
• Actively train employees and third-party agents to ensure they understand sanctions compliance obligations, as well as how to recognize and address sanctions compliance.
• Implement a risk-based sanction screening process tailored to the specific nature, size, and risk of your business operations.
• Align sanction screening to third-party due diligence procedures including consistent, sanction, watch list and PEP checks during due diligence.
• Ensure procedures include escalation contacts, both for sanction enquiries and violation reporting.
• Implement ongoing third party risk monitoring across sanctions, watchlists, blacklists, PEPs and SOEs, as well as adverse news and company financial data to stay alert to emerging threats.
• Audit and regularly review sanction screening policies, procedures, and training to ensure your processes keep pace with change.
• Reinforce policies and procedures with independent audits and testing.

Don’t wait for an enforcement action to put these best practices in place. Arrange a free trial of Nexis Diligence to see how it enables sanctions due diligence and more!