Designing a governance framework for sanctions

Firms are required to ensure compliance with global sanctions regimes and export controls to prevent terrorism and organised crime. In order to meet these requirements, they will need to monitor regulatory changes and maintain an internal framework to ensure that customers, third parties and transactions do not breach sanctions rules.

The framework may typically include:

• Documented policies and procedures
• Monitoring and screening systems against sanctions lists
• Forums with a sanctions agenda
• Clear roles and responsibilities
• Escalation processes
• Requirements for reviewing sanctions-related processes reporting requirements.

Each firm will integrate bespoke parameters into its sanctions programme in line with its business risk appetite. For example, certain US rules may not be applicable in the UK, but these requirements may be included in sanctions controls across the firm owing to the Join JMLSG‘s exposure to the US by virtue of its global presence and business activities.

The firm’s sanctions policy and procedures should be revised at least annually, and regulatory and policy developments need to be communicated accordingly.