SANCTIONS COMPLIANCE FOUNDATIONS

Course Syllabus

Sanctions compliance is a fundamental element of a robust and effective

financial crime prevention program. Breaches can result in substantial
financial penalties and reputational damage. To remain compliant, you need
to understand how sanctions regulations impact your business.

This foundation course will introduce you to the principles underpinning

sanctions compliance, help you understand your own unique risk, and what
controls should be applied.

What you’ll learn:

• How sanctions are created and enforced

• The different sanctions types, their targets and exceptions
• The jurisdictional reach of sanctions and to whom the concept applies
• How violations happen and how to prevent them
• What a robust sanctions compliance program looks like
• How to conduct sanctions due diligence
• What sanctions screening is and how it is applied
• Investigating and reporting sanctions breaches

Participants of this course may be early in their compliance career, learning

about sanctions for the first time, professionals seeking a refresher course or
those looking to progress to our flagship Certified Global Sanctions
Specialist (CGSS) qualification.

© 2021 ACAMS. All Rights Reserved. Sanctions Compliance Foundations Course Syllabus 1
This information is subject to change. Updated 04 March 2021
Course Structure:

• Online and self-paced

• 4 hours of coursework
• 4 weeks to complete
• 20-question final assessment

The minimum passing score is 80% and multiple attempts are allowed. When
you pass, you’ll receive an online certificate and earn 4 ACAMS credits.

Technical Requirements:

The course is compatible with most operating systems and browsers. The
ACAMS Learning Management System (LMS) can be accessed at https://lms.
acams.org. If your access to our LMS portal is blocked, please contact your
organization’s IT department for assistance.

Course Content:
1. Getting Started

Introduction

• DPRK Services case

• What would you do?
• Feedback

2. Sanctions origins and legal framework

What are sanctions and why do they exist?

• Sanctions
• History of sanctions
• Sanctions: National and international security

© 2021 ACAMS. All Rights Reserved. Sanctions Compliance Foundations Course Syllabus 2
This information is subject to change. Updated 04 March 2021
 How are sanctions created and enforced?

• Who imposes sanctions?

• United Nations sanctions regime
• European Union sanctions regime
• United States sanctions framework
• United States sanctions regulatory agencies
• United Kingdom sanctions regime
• Unilateral sanctions
• Influential organizations
• CPF / CFT
• UN sanctions regime (Case example)

3. Sanctions types, targets, and exceptions

What are the types of sanctions?

• Types of sanctions and embargoes

• Financial and economic sanctions
• Asset freeze and making funds available
• Trade sanctions including arms embargoes
• Trade sanctions: Items subject to export control
• Comprehensive vs targeted sanctions
• Sectoral sanctions

Are there exceptions made for sanctions?

• Sanctions exceptions, exemptions, and licenses

• Grounds for sanctions licensing
• Effective application of humanitarian licenses
• Managing indirect sanctions exposure (Case example)

© 2021 ACAMS. All Rights Reserved. Sanctions Compliance Foundations Course Syllabus 3
This information is subject to change. Updated 04 March 2021
4. Jurisdictional reach of sanctions

What is the jurisdictional reach of sanctions and who is subject to them?

• US primary vs secondary sanctions

• Who needs to comply with sanctions?
• US-origin goods and technology
• Jurisdictional reach of US secondary sanctions
• US secondary sanctions and significant transactions
• US-origin goods and technology (Case example)
• Jurisdictional cross-border legal and regulatory conflicts
• Sanctions blocking regulations (Case example)

5. Sanctions violations

How do sanctions violations occur?

• Unintentional sanctions violations

• Sanctions evasion techniques: Payments
• Sanctions evasion techniques: Trade-based
• Sanctions evasion techniques: Trade-based maritime (Case example)
• Lessons from enforcement

What are the consequences for not following sanctions

• Consequences: Regulatory, financial, reputational

• Consequences: Regulatory, financial, reputational (Case example)

6. Sanctions compliance program

What aspects form a robust and effective SCP?

• Framework for a robust SCP

• Management commitment / culture of compliance
• Sanctions risk assessment

© 2021 ACAMS. All Rights Reserved. Sanctions Compliance Foundations Course Syllabus 4
This information is subject to change. Updated 04 March 2021
 • Internal controls
• Testing and audit
• Sanctions compliance training
• Staying current on sanctions
• Sanctions easing and lifting
• Sanctions easing and lifting (Case example)

Identifying and managing sanctions risk

• Principles for an effective SRA

• Categories of customer risk: Customer, jurisdiction, product, channel
• Sector-specific sanctions risks (Introduction)
• Correspondent banking sanctions risk
• Digital currencies sanctions risk
• Corporate supply chain sanctions risk
• Corporate supply chain sanctions risk (Case example)
• Maritime, logistics, and freight forwarders sanctions risk
• US-origin goods and technology (Reminder)
• Technology sector sanctions risk
• High-value and luxury goods sanctions risk
• Effective application of humanitarian licenses (Reminder)
• Humanitarian delivery in sanctioned jurisdictions

7. Sanctions due diligence

How do I conduct sanctions due diligence?

• Know your customer requirements

• Know your customer due diligence
• Enhanced due diligence for sanctions
• Due diligence investigations for sanctions (Case example)

© 2021 ACAMS. All Rights Reserved. Sanctions Compliance Foundations Course Syllabus 5
This information is subject to change. Updated 04 March 2021
 Understanding beneficial ownership

• Transparency, ownership, and control

• OFAC 50% rule
• EU and UK ownership and control
• Concealment of beneficial ownership
• KYC due diligence (Case example)
• OFAC 50% rule (Case example)

8. Sanctions screening, investigation, and incident management

What is sanctions screening and how does it work?

• Sanctions screening
• Types of sanctions screening
• Sanctions Screening: Amazon (Case example)

What do we do when the risk emerges?

• Dealing with a sanctions breach

• Self-reporting a potential breach of sanctions
• Incident management as part of an SCP
• Sanctions Compliance Foundations (Summary)

© 2021 ACAMS. All Rights Reserved. Sanctions Compliance Foundations Course Syllabus 6
This information is subject to change. Updated 04 March 2021