Global sanctions, embargoes and other trade restrictions pose significant compliance, regulatory and reputation risk. On an ongoing basis, risk and compliance officers, in consultation with legal advisors, need to determine if their customer and partner data is up-to-date and complete, and if their controls are sufficient to both comply with regulations and keep up with the changing landscape.
Financial institutions need to understand the impact of sanctions and trade restrictions on their businesses, especially in times of crisis when they must respond very quickly to complex and evolving requirements.
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Financial institutions and their clients must comply with an expanding list of complex sanctions and trade restrictions, often requiring that they pivot immediately to address new requirements. Protiviti can help financial institutions assess their sanction-related risks and advise them on the control environment and industry best practices for managing the risks of compliance with sanctions and trade restrictions.
Protiviti assists financial institutions by enhancing their sanctions processes and controls in the following ways:
Identify an institution’s inherent risk to sanctions risk from its customer base. Products/ services and geographic reach and the controls in place to mitigate these risks.
Review governance and reporting to senior management and boards of directors, review inadvertent breaches and assist with lessons learned analyses and enhancements; provide bespoke training.
Determine whether lists used for screening are complete and whether adequate manual monitoring processes exist where automated screening may not provide complete coverage, e.g., trade finance.
Perform independent tuning and validation of models used for sanctions screening to ensure they are optimized and operating as intended.
Assist with operational planning and processing including providing additional resources as needed
Perform an internal audit or second line review of an institution’s sanctions compliance program.