1. Raise awareness in your organisation
The first step to putting in place a robust compliance programme is to ensure that everyone in the organisation is aware of the importance of sanctions compliance and their obligations in this regard. This policy should document how and when to perform risk assessments, transaction monitoring and screenings.
2. Embed sanctions compliance into commercial operations
It is no longer good enough for sanctions compliance to rest solely with the legal and compliance team. In many organisations, these teams simply cannot deal with the level of due diligence required for every potential check.
3. Leverage technology to minimise risk
Manually completing checks to a high standard is both time-consuming and expensive. Beyond the costs, it is open to human error, with the risk of both false negatives and false positives being raised. The dynamic nature of sanctions also means that keeping abreast of constant changes is difficult to do wholly manually.
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