GACO, GBA and UK Finance Sanctions Seminar - Mastering Sanctions in Practical Terms - 12th June 2024

While the scale and extent of sanctions is a modern development, they have a lengthy pedigree, having been used since ancient times. In fact, the first recorded use of sanctions results from a dispute between Athens and Megara, a neighbouring city state, in around 430 BC.

After the inhabitants of Megara cultivated consecrated land and killed an Athenian herald, Athens imposed what we would now recognise as trade sanctions. In particular, Megara’s traders were excluded from Athenian markets, including the ports in its empire.
 
Economic and trade sanctions are restrictions put in place by national governments and global intergovernmental organizations to achieve foreign policy, national security, and crime reduction objectives.

Sanctions work by limiting access to financial systems, blocking trade, and freezing assets connected to sanctioned parties. The goal is to change the target’s behaviour by isolating them from national and international finance and trade. 
 
Sanctions compliance refers to the internal policies and procedures companies implement to ensure they adhere to applicable sanctions regimes. Sanctions compliance programs involve screening customers, suppliers, and transactions to avoid violating restrictions. Through sanctions compliance measures, companies avoid inadvertent violations as rules frequently change. Structured programs also mitigate regulatory and criminal liability risks if violations do occur.
 
Given the importance of sanctions and the cost of noncompliance, firms should be familiar with sanctions screening best practices to ensure their compliance programs deliver the required results.
 
Understanding the intricacies and challenges of meeting sanctions obligations and implementing a framework to manage sanctions risks is vital for regulatory and financial crime compliance professionals. Sanctions remain a complex yet fascinating topic and crucial for developing a well-rounded strategy in combating financial crime. 
 
However, some businesses struggle with understanding the requirements and challenges of managing sanctions screening and sanctions risk. With different sanctions lists to consider, varied regulations to comply with, and the potential for significant financial costs and penalties, businesses are in search of guidance to navigate this complex process.
 
Sanctions regulations and policies are subject to rapid change and staying informed about national and global developments is essential for compliance. Violations can result in substantial fines and damage to reputation, affecting customer trust and investor confidence. Financial institutions must strike a balance between complying with such regulations and pursuing profitable business opportunities, especially in regions or sectors with high sanctions exposure.

Adhering to national and global sanctions requires a proactive and comprehensive approach that includes clear governance, policies and procedures, systems and tooling, continuous learning, change management, audit and testing, training, and reporting and communication. Financial institutions must invest to establish a robust framework and compliance culture to adhere to relevant laws and regulations and avoid (un)knowingly facilitating sanctioned parties or contributing to evasion or circumvention. Collaboration with legal, compliance and sanctions experts is essential to an effective sanctions’ compliance program.
 
Therefore GBA and GACO are happy to have engaged  the following Specialists from UK Finance ("Representing 300 firms, we’re a centre of trust, expertise and collaboration at the heart of financial services. Championing a thriving sector and building a better society”) to explain to all our members how you deal in practical terms with Sanctions and avoid all the negative side effects of the same: 

Neil Whiley - Director Sanctions & Export Controls

Neil oversees the UK Finance sanctions and export controls programme and has worked in financial services for over 25 years, specialising in sanctions compliance since 2009. Prior to joining UK Finance, Neil had worked within sanctions remediation at a number of banks. Working closely with industry, government, regulators and educators, Neil aims to make sanctions and export control requirements clear and easier to understand. Neil regularly promotes CPD and diversity & inclusion.

Anila Haleem, Principal Sanctions & Export Controls

Anila is a former Barrister at Law and acts on behalf of the financial sector as Principal Sanctions & Export Controls within the Economic Crime Team at UK Finance, the trade body representative for over 300 financial institutions. Responsible for advancing corporate compliance with international regulatory bodies, Anila leads the monitoring and consults on applicable sanctions and its intersection with export controls, proliferation finance and AML provisions across multiple jurisdictions with cross-industry sectors. 

Founder of the UK Finance Women in Sanctions Forum and Co-host of the UK Finance Sanctions School Podcast series, Anila is widely celebrated for her collaborative efforts in bridging the gap as a generational leader, promoting Diversity, Equity & Inclusion.

Ed Pίška - Analyst, Sanctions and Export Controls

Ed brings a deep understanding of government institutions and public policy to the Sanctions and Export Controls team, following three years as a Home Office and Ministry of Justice policy researcher to Chris Philp MP, and a stint in Public Affairs.

On joining UK Finance, Ed advocated on behalf of the sector during the passage of the Economic Crime and Corporate Transparency Act. Since joining the Sanctions team in 2023, he now leads on the industry Intelligence Sharing Working Group, delivers regime monitoring analysis, in addition to promoting Parliamentary engagement and supporting on wider stakeholder engagement.

Furthermore, we are happy to inform you that The HON Albert Isola CBE, Senior Partner of Isolas will deliver the introductory speech to this seminar. 

Albert was elected into the Gibraltar Parliament on the 4th July 2013 and successfully re-elected in 2015 and 2019 with the GSLP-Liberal Alliance. Throughout this time he has held significant Ministerial responsibilities.

List of responsibilities have included;

• Minister for Financial Services and Gaming; 2013 – 2023
• Minister for Digital Services; 2015 – 2023
• Minister for Commerce and the Port; 2015 – 2019
• Minister for Town Planning; 2019 – 2022
• Minister for Broadcasting, and Public Utilities; 2019 – 2023
• Minister for Health and Care; 2022 – 2023
• During his entire tenure Albert has held responsibility for the Financial Services and Gaming portfolios which together account for some 50% of Gibraltar’s GDP. These areas have both grown substantially during his tenure.

Of note;

He has held responsibility for financial services policy, product development, and responding to international initiatives including those on exchange of information, anti-money laundering, transparency and international tax compliance. As such he has worked  closely with the financial services regulator, the Financial Services Commission and the Gibraltar Gambling Commissioner.

Particularly noteworthy is his leading role in the establishment and development of the Gibraltar International Bank, a first for Gibraltar as a Government wholly owned full-service credit institution dedicating itself to retail banking for the community. The Bank managed by its Executives and with an independent Board has grown rapidly with profits for this year anticipated to reach £10M.

Albert also in 2018 launched Gibraltar’s world first legal framework for the licensing and regulation of Distributed ledger technology firms. Years ahead of any competitors and highly regarded today by all participants in the industry.

Albert has also driven significant reform in his areas of responsibility including a modern and fit for purpose new Financial Services Act (2019) updating and consolidating some 80 pieces of legislation into a new legislative framework for the Industry working closely with HMT in London and UK regulators to ensure alignment with the UK’s regulatory framework. He has also led all discussions on the Gibraltar Authorisation Regime under the UK Financial Services Act granting Gibraltar’s firms exclusive access to the UK Markets post Brexit.

Albert has also drafted a new Gambling Bill to propose to Parliament encompassing a new legal and regulatory regime for future generations of Gambling firms in the Jurisdiction. This is expected to be published shortly.

Prior to re-entering Parliament in 2013, Albert had been a Partner at ISOLAS from 1985 to 2013, to which he has now returned.

In January 2024 Albert was appointed by King Charles III to be a Commander of The Most Excellent Order of the British Empire (CBE) for services to the financial and digital industries in Gibraltar.

Albert was educated at Stonyhurst College, Lancashire (1973 to 1980) and read Law at Kingston University (1980 to 1983). He is married to Graziella and has 4 children, Albert, Georgina, Tamara and Rosie.

Event type: in-person seminar
Venue: Borealis Room, Sunborn Yacht Hotel, Gibraltar
Date: 12th June 2024
Time: 09:00 - 09.30hrs welcome coffee; 9.30hrs - 12.30hrs Seminar (there will be a coffee break at around 11.00am)
Fee: £35 GBA & GACO Members, £50 Non-GBA & Non-GACO Members