ACI's Virtual Proficiency Series in Economic Sanctions - DS

Join this immersive, practical 4-week Economic Sanctions Masterclass!

EARN CLE CREDITS

Virtual Proficiency Series

ECONOMIC SANCTIONS

February 6 – 29, 2024 • Tuesdays & Thursdays • 1:30 – 4:30pm (EST)

Your 1 Month Passport to Economic Sanctions Proficiency:

Real-World Guidance From:

CALENDAR-ALT Convenient and easy-to-follow:

y Bank of the West

4 weeks, 2 sessions/week

Clock 7 in-depth modules, 21 hours of training

video 8 session recordings for future reference pencil Actionable takeaways for your work

File-Alt edit

Substantive, speaker-prepared resource materials

y BNP Paribas

Hands-on practical sessions using hypothetical scenarios

y DWS Group

Certificate of completion & CLE credits

y Honeywell

Comments Dedicated Q&A sessions with expert faculty

y HSBC

AmericanConference.com/Proficiency-Sanctions • US - 1 888 224 2480 CA - 1-877-927-7936 UK - +44 (0) 20 4532 2313

y SAP y SEKO Logistics y Sumitomo Mitsui Banking Corporation y Standard Chartered Bank

Part of ACI’s PROFICIENCY SERIES

ECONOMIC SANCTIONS TRAINING Your Building Blocks for Economic Sanctions Proficiency WEEK ONE:

WEEK TWO:

MODULE 1: Feb. 6, 2024 • 1–4pm EST

MODULE 3: Feb. 13, 2024 • 1–4pm EST

Your U.S. Economic Sanctions Roadmap – Key Concepts, Agencies, Jurisdictions and Roles MODULE 2: Feb. 8, 2024 • 1–4pm EST

RUSSIA: A Deep Dive into the Latest Russia Sanctions Compliance and Screening Requirements

WEEK THREE:

CHINA: OFAC Guidance and Risk Mitigation – and the Impact of China’s Retaliatory Measures MODULE 4: Feb. 15, 2024 • 1–4pm EST

Primer on EU and UK Sanctions – and the Similarities and Differences with U.S. Restrictions

MODULE 5: Feb. 20, 2024 • 1–4pm EST

A Roadmap to U.S. Sanctions on Iran, Cuba, Venezuela, Syria, North Korea, Iran, Afghanistan, Belarus MODULE 6: Feb. 22, 2024 • 1–4pm EST

The Essentials to an Effective Global Sanctions Compliance Program: Lessons Learned from Key and Recent Enforcement Actions

WEEK FOUR: MODULE 7: Feb. 27, 2024 • 1–4pm EST

How to Submit an Application to the OFAC Licensing Division

MODULE 8: Feb. 29, 2024 • 1–4pm EST

Review of Proficiency Assignment and Q & A: Working the Regulators

Professional Development to Help You Succeed on the Job Your Blueprint to Proficiency: Immersive and Practical

Connect: Build Your Network and "Brain Trust"

y Interactive format that encourages dialogue with attendees and speakers

y Build Your “Brain Trust” by connecting with likeminded professionals

y Convenient and easy to follow: Fits around your schedule, 2 times per week in easy-to-follow blocks focused on what you really need for your work

y Develop your sounding board and global network of community peers

Real Life, Not Textbook y Expert speakers will take you through concrete experiences and “war stories”

y Access a highly respected, diverse faculty with verified subject-matter expertise and track records y Join dedicated Q&A sessions with expert faculty

y Actionable takeaways for your work: Sharpen your knowledge and skills for success on the job

WHO SHOULD ATTEND? Vice Presidents, Managers and Counsel working in: y OFAC Compliance

y Regulatory Compliance

y Global Sanctions

y International Trade

y AML

y Compliance

y Financial Crime

Outside Counsel Specializing in y y y y y

Economic Sanctions OFAC International Trade Financial Services AML and Financial Crime

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MEET OUR EXPERT INSTRUCTORS Huma Ahmed Global Head of Sanctions DWS Group

Lila Landis Chief Compliance Officer SEKO Logistics (WSN Member)

Phillip Byrnes Deputy Head, Sanctions & Head, Group Sanctions Specialist Team Standard Chartered Bank

Roy Liu Partner Akin Gump LLP

Perry Bechky Partner Berliner Corcoran & Rowe LLP Laura Deegan Counsel Miller & Chevalier Chartered Darshak Dholakia Partner Dechert LLP Maeva Donlin Sanctions Advisory Lead, VP Bank of the West (WSN Member) Ginger Faulk Partner Eversheds Sutherland Dara Fernandez Perez General Counsel for Trade Sanctions (EMEA) Honeywell Sarah Haggarty Sanctions Compliance Officer Office of Foreign Assets Control U.S. Department of the Treasury Jen Inman Director Export Controls SAP Erin Lahey Deputy Head of Group Financial Security OFAC Sanctions Advisory BNP Paribas (WSN Member)

Jeanette Miller US Head of Sanctions Regulatory Response & Development HSBC (WSN Member) Daragh O’Shea Partner Mason Hayes & Curran Christopher Penaherra Senior Compliance Officer Office of Foreign Assets Control U.S. Department of the Treasury Nick Price Partner Osbourne Clark LLP

Real-Life Benefits of Attending: ĉ ADVANCE your career and professional development by becoming proficient in the essentials of Economic Sanctions ĉ ADD VALUE to your organization with a practical roadmap for compliance, screening, licensing and risk management ĉ CONNECT with a global community of economic sanctions peers

Jamie Schafer Partner Perkins Coie LLP Will Schisa Counsel Davis Polk & Wardwell LLP Waqas Shahid Vice President, Forensic Services Charles River Associates Igor Sololev Director, Financial Crime Prevention Unit, Sanctions Sumitomo Mitsui Banking Corporation Shrutih Tewarie Partner Foley Hoag LLP

AmericanConference.com/Proficiency-Sanctions • US - 1 888 224 2480 CA - 1-877-927-7936 UK - +44 (0) 20 4532 2313

Part of ACI’s PROFICIENCY SERIES

WEEK ONE February 6, 2024 | 1:30-4:30 (EST) Module 1: Your U.S. Economic Sanctions Roadmap – Key Concepts, Agencies, Jurisdictions and Roles – and Who to Contact for What Erin Lahey

Deputy Head of Group Financial Security OFAC Sanctions Advisory BNP Paribas (WSN Member)

Jen Inman

Will Schisa

Director Export Controls SAP

Counsel Davis Polk & Wardwell LLP

During this practical opening session, expert instructors will take you through the key agencies involved in U.S. sanctions implementation and enforcement and the evolving framework of U.S. Secondary Sanctions and Human Rights-related actions including: • Basics of sanctions law: e.g., TWEA, IEEPA, Executive Orders, and Designations » Introduction to OFAC, BIS, DOJ, State Department, Congress and how they work together » U.S. Sanctions Jurisdiction: Extra-Territoriality » What are Primary, Sectoral, and Secondary Sanctions?

• Introduction to OFAC’s 50% Rule » Key Licenses and Exemptions » Sources of Guidance: Alerts, FAQs, and Enforcement Actions » Intersection of Economic Sanctions, Export Controls and ore National Security Areas

• Human Rights and Supply Chain Considerations » Sanctions in Context: Import Controls, Export Controls, and Sanctions to Target Human Rights Violations and Abuses » Human Rights-related Sanctions: e.g., Global Magnitsky, Burma, Belarus, Xinjiang, and Hong Kong • Economic Sanctions and Export Controls » How economic sanctions and export controls interact-and their increasing interplay » Key agencies responsible for implementing and enforcing export controls-and their coordination and overlap with OFAC, BIS, DOJ and more

• Secondary Sanctions » Scope: Menu-based versus Designations » Application in Practice » Financial Institution Considerations

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WEEK ONE February 8, 2024 | 1:30-4:30 (EST) Module 2: RUSSIA: A Deep Dive into the Latest Russia Sanctions Compliance and Screening Requirements Igor Sololev

Director, Financial Crime Prevention Unit, Sanctions Sumitomo Mitsui Banking Corporation

Laura Deegan

Counsel Miller & Chevalier Chartered

Sarah Haggarty

Sanctions Compliance Officer Office of Foreign Assets Control U.S. Department of the Treasury

Summary of Current Program:

Key Compliance Issues & Predictions for the Next 6-12 Months:

• Overview of framework for current Russian program » Which authorities are implementing Russia-related restrictions?

• Ownership & Control Assessment » US 50% Rule

» Comprehensive review of Russian sanctions evolution and what is on the horizon.

• “Who” Based Restrictions » Asset freezing restrictions including primary targets (banks, oligarchs, politicians, defense industry) • ““Where”” Based Restrictions » Embargoes on Ukrainian occupied territories occupied by Russia • “What” Based Restrictions » Trade Controls: Export & Import Restrictions » Professional Services Ban » Investment bans » Capital market/ securities restrictions. » Targeting of certain sectors in Russia(defense, energy and financial)

» EU/UK Ownership & “Control” Analysis: How can you prove control?

• Export Controls » Rising expectations on financial institutions (FinCEN Advisory) » Integration of export and import functions and use of HTS. » “Technical assistance” and related services controls » Diversion • Enforcement » Publicly identified actions to date » Expected regulator pivot to investigation and enforcement as rules stabilize. » Cross-border investigations and cooperation (including US-UK) • Where are we headed? » One-way ratchet on restrictions with a long-time frame » Designations / export controls / restricted services » Considerations for remaining in Russia. » Lessons learned for exiting Russia-and the possible roadblocks.

AmericanConference.com/Proficiency-Sanctions • US - 1 888 224 2480 CA - 1-877-927-7936 UK - +44 (0) 20 4532 2313

Part of ACI’s PROFICIENCY SERIES

WEEK TWO February 13, 2024 | 1:30-4:30 (EST) Module 3: CHINA: Comprehensive Analysis of Recent OFAC Guidance on China Risk Mitigation for Your Operations – and the Impact of China’s Retaliatory Measures Lila Landis

Chief Compliance Officer SEKO Logistics (WSN Member)

Darshak Dholakia

Roy Liu

Partner Dechert LLP

• The Essentials of U.S. Sanctions on China » DPRK and Iran-related designations of Chinese entities » Use of Entity List » Xinjiang and human rights-related designations, and the interplay with UFLPA » CMIC sanctions » FCC Covered List and government procurement bans » Contrasting Biden v. Trump Administration policies » Upcoming restrictions on certain investment in Chinese AI and other companies » 2005 Section 311 designation of Banco Delta Asia • Chinese Blocking Statute (passed January 2021) » Reporting requirement on Chinese companies » Prohibition on compliance with “foreign law” » Private right of action » Identification of “extraterritorial” laws status » Pending identification of “extraterritorial” laws

Partner Akin Gump LLP

• Chinese Retaliation » China’s Anti-Foreign Sanctions Law (passed June 2021) » Risk retaliatory measures for compliance with foreign sanctions in China » Exposure to countersanctions by Beijing against persons or entities instigating or implementing sanctions » Retaliation for U.S. and EU sanctions over Xinjiang and Hong Kong • Chinese Data Security Law (passed June 2021) » New data security law, effective September 1, 2021, requiring all companies in China to classify data » New rules regarding “critical information infrastructure.” » Ambiguous classification and handling requirements » How will these new rules be enforced? » China’s Unreliable Entity List » Chinese consumer backlash

» Potential for aggressive enforcement compared with the EU » How to address balance compliance with Chinese laws and US sanctions

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WEEK TWO February 15, 2024 | 1:30-4:30 (EST) Module 4: A Complete Primer on EU and UK Sanctions-and the Similarities and Differences with U.S. Restrictions Jamie Schafer Partner Perkins Coie LLP

Nick Price

Partner Osbourne Clark LLP

Daragh O’Shea

Partner Mason Hayes & Curran

This session will provide you with a complete guide to the EU and UK Sanctions landscapes-and their application to European, U.S. and other foreign-owned multinationals. The US has worked closely with the UK and Europe on sanctions implementation, however, there still remains many differences and nuances amongst all three sanctions regimes.

Topics of discussion to include: • Demystifying EU/UK Sanctions Regimes: » Asset Freezes and Travel Bans » “Any Transaction” Prohibition » Restrictions on SWIFT access for financial institutions » Investment restrictions » Oil Price Cap

• Key Differences across US, EU, and UK for Russia » “Transactions” Prohibitions: US & EU » Limited list-based sanctions: the “sectoral” sanctions program current • Examining EU Regulations and Member State implementation and enforcement • Review of UK sanctions and export controls – OFSI and DIT implementation • Comparing and contrasting EU, UK, and US sanctions

» Professional services ban » 11th EU Sanctions Package

AmericanConference.com/Proficiency-Sanctions • US - 1 888 224 2480 CA - 1-877-927-7936 UK - +44 (0) 20 4532 2313

Part of ACI’s PROFICIENCY SERIES

WEEK THREE

February 20, 2024 | 1:30-4:30 (EST)

Module 5: Deciphering Country-Specific Sanctions: A Roadmap to U.S. Sanctions on Iran, Cuba, Venezuela, Syria, North Korea, Afghanistan, Belarus Phillip Byrnes

Deputy Head, Sanctions & Head, Group Sanctions Specialist Team Standard Chartered Bank

Huma Ahmed

Ginger Faulk

Global Head of Sanctions DWS Group

Iran

Partner Eversheds Sutherland

Syria

• Jurisdictional scope

• Government of Syria and state-owned entities are blocked

• Impact of recent developments

• Export embargo, ban on export of services and certain categories of investment

• Evolution of the U.S. embargo since JCPOA withdrawal

• Humanitarian licensing

• Other, overlapping sanctions: IRGC, SDGT, NPWMD, etc.

• Frequently used general licenses and their practical limitations • Broad array of secondary sanctions authorities • Section 13(r) of the Exchange Act: SEC reporting requirements for public companies

Cuba • More expansive jurisdictional scope than other programs • Differences in exemptions (no travel exemption under TWEA) and civil penalties (TWEA’s statutory maximum penalties are lower)

North Korea • Government of North Korea and state-owned entities are blocked • Foreign subsidiaries of US financial institutions are prohibited from transacting with the • Government of North Korea or certain North Korean SDNs: How does this play out in practice?

• Investment in, exports to, and imports from North Korea are prohibited • “Secondary sanctions” risks

Afghanistan

• Broad prohibitions apply to all Cuban nationals

• What sanctions continue in effect?

• General licenses allowing dealings with Cuban nationals permanently residing outside of Cuba

• General licenses authorizing certain humanitarian activity by NGOs and international organizations

Venezuela • The Government of Venezuela (GoV) and state-owned entities including PdVSA are blocked

• The scope of limits on fund transfers to the Taliban and the Haqqani Network, including in relation to authorized humanitarian activity

Belarus

• Various other sanctions apply to Venezuelan bonds, new debt, purchases of securities from the GoV, pledges of collateral by the GoV, and transfers of equity interests owned by the GoV

• Overlap with Russia sanctions

• Blocking sanctions have been imposed on persons operating in certain sectors

• Increased use of sanctions to respond to human rights violations

• Discussion of key general licenses, including broad authorizations for CITGO-related transactions and Chevron operations

• Risk of SDN designation for companies in certain sectors

• Increasing use of targeted SDN designations and coordination with the UK and EU

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WEEK THREE

February 22, 2024 | 1:30-4:30 (EST)

Module 6: The Essentials to an Effective Global Sanctions Compliance Program: Lessons Learned from Key and Recent Enforcement Actions Maeva Donlin

Sanctions Advisory Lead, VP Bank of the West (WSN Member)

Waqas Shahid

Vice President, Forensic Services Charles River Associates

Shrutih Tewarie Partner Foley Hoag LLP

Understanding sanctions enforcement is critical for developing and strengthening an effective global sanctions compliance program. Our experienced instructors will unpack the essentials of U.S. sanctions enforcement, including the decision to voluntarily disclose to OFAC, the potential consequences of an OFAC enforcement action, and key lessons from recent cases.

• Recent Key Enforcement Actions and Lessons Learned » Geofencing and IP address blocking

• How Sanctions Enforcements and Disclosures Arise » Internal investigations and blocking or rejecting reports.

» Counterparty screening, due diligence, and / or compliance procedures » Leveraging technological tools for sanctions compliance purposes.

» Notices from other parties » Responding to OFAC subpoenas and requests for information.

» Preparing a voluntary self-disclosure. » Remediation and corrective actions

» Considerations for whether or not to make a voluntary self-disclosure.

» OFAC’s enforcement guidelines and penalty calculations » Civil versus criminal enforcement / liability » Supply chain due diligence » Parent and successor liability

• Potential Enforcement Outcomes » No action letters, cautionary letters, finding of violations, settlements, penalty notices, and criminal referrals. » Public versus private dispositions » Sanctions enforcement as punishment and policy

» U.S. sanctions jurisdiction over non-U.S. persons

Hypothetical Exercises, Q & A and Review on the Do’s and Don’ts Toward solidifying your understanding of the enforcement process, the instructors will take you through a series of hypothetical scenarios to help you apply and understand voluntary self-disclosure best practices. At the end of this module, instructors will provide additional clarification and guidance, and take your questions.

AmericanConference.com/Proficiency-Sanctions • US - 1 888 224 2480 CA - 1-877-927-7936 UK - +44 (0) 20 4532 2313

Part of ACI’s PROFICIENCY SERIES

WEEK FOUR

February 27, 2024 | 1:30-4:30 (EST)

Module 7: How to Submit an Application to the OFAC Licensing Division: Practical Guidance for Preparing Your Submissions – and Minimizing the Risk of Delays and Denials Perry Bechky

Jeanette Miller

Partner Berliner Corcoran & Rowe LLP

US Head of Sanctions Regulatory Response & Development HSBC (WSN Member) • How to Submit a Specific License Application for Transactional Requests » The information necessary for OFAC to consider the application “complete.” » Differences and similarities between a specific license application and a request for interpretive guidance on general licenses » The role of an OFAC Statement of Licensing Policy or FAQs in a license application » The interagency process – the roles of the State Department and/or Commerce Department in certain types of applications

• Other Types of OFAC Licensing Communications » General License Guidance Letters – what do these do? » Denial Letters – what happens if your license application is denied • When and How to Contact OFAC » Understanding the timing of getting an OFAC response » The difference between a formal OFAC determination and the OFAC Compliance hotline

• How to Submit a License Application for the Release of Blocked Funds » How does this type of license application differ from a Transactional Request? » Types of information required for OFAC to process the application » What is the process for these types of applications?

WEEK FOUR

February 29, 2024 | 1:30-4:30 (EST)

Module 8: Practical Guidance for Working Effectively with OFAC and Review of Proficiency Exam Sarah Haggarty

Sanctions Compliance Officer, Office of Foreign Assets Control U.S. Department of the Treasury

Christopher Penaherra

Senior Compliance Officer, Office of Foreign Assets Control U.S. Department of the Treasury

Laura Deegan Counsel Miller & Chevalier Chartered

In advance of this last unit, participants will complete an assignment on various sanctions scenarios. The questions will be based on real-world case studies. During this last session, participants will share their responses to the assignment questions, followed by in-depth feedback from the expert instructors.

In the first half of this session, faculty will discuss how to effectively work with OFAC, OFSI, and the EU Commission. Topics to be discussed include: • Understanding how OFAC, OFSI, and the EU Commission are structured.

• Importance of Communication with regulators

• The importance of FAQs

• How to best get your questions answered

• Reporting to OFAC, OFSI, and the EU Commission

Award of “Passport to Proficiency” Participants who have completed all Modules will receive a certificate reflecting their proficiency in the essentials of Economic Sanctions

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Upcoming Events New York Forum on

ECONOMIC SANCTIONS December 13 – 14, 2023 New York Bar Association, New York, NY

Annual Flagship Conference on

AML & OFAC COMPLIANCE for the Insurance Industry

U.S. ECONOMIC SANCTIONS

February 13 – 14, 2024 New York City Bar Association, New York, NY

April 29 – 30, 2024 The National Press Club, Washington, DC

ENFORCEMENT AND COMPLIANCE

Join this exclusive legal and compliance cross-industry community!

WOMEN IN SANCTIONS NETWORK

The Women in Sanctions Network (WSN) is a global community of like-minded women working in economic sanctions. The WSN is committed to promoting diversity across the profession, creating worthwhile networking and educational programs, and updating members on employment and advancement opportunities .

Join our Women in Economic Sanctions Membership: WomenSanctionsNetwork.com

AmericanConference.com/Proficiency-Sanctions • US - 1 888 224 2480 CA - 1-877-927-7936 UK - +44 (0) 20 4532 2313

Part of ACI’s PROFICIENCY SERIES

Join Us Virtually this February!

Participate in Meaningful Networking Emma McAdam VP, Government Affairs

Janet Smith VP, General Counsel

Olivia Thomson Chief Compliance Officer

Luis Santos Director

Enjoy an Easy to Use, Dynamic Online Platform Engage with Attendees and Speakers in an Interactive Format

Ramesh Kumar Partner

Jean Roux VP, Business Development

Real-World Guidance From: y Bank of the West

y HSBC

y BNP Paribas

y SAP

y DWS Group

y SEKO Logistics

Sumitomo Mitsui Banking Corporation

Meet 1-on-1 with Your Fellow Attendees

Patricia Harden Head of Sanctions Miyuki Johnson VP, Manufacturing

y Standard Chartered Bank

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EARN CLE CREDITS

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