Virtual Proficiency Series Economic Sanctions 2025 - DS

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ECONOMIC SANCTIONS Virtual Proficiency Series

March 4 – 27, 2025 • Tuesdays & Thursdays • 1:30 – 4:30pm (EST)

Your

CALENDAR-ALT Convenient and easy-to-follow: 4 weeks, 2 sessions each week

Clock 8 in-depth modules, 24 hours of training

Certificate of completion & CLE credits

pencil Actionable takeaways for your work, with recordings of each module available for you to review at your own convenience.

File-Alt Substantive, speaker-prepared resource materials

edit Hands-on practical sessions using hypothetical scenarios

Comments Dedicated Q&A sessions with expert faculty

ECONOMIC SANCTIONS TRAINING

Your Building Blocks for Economic Sanctions Proficiency

WEEK ONE: WEEK TWO: WEEK THREE: WEEK FOUR:

MODULE 1 :

March 4, 2025 • 1:30–4:30pm EST

Your U.S. Economic Sanctions Roadmap: Key Concepts, Agencies, Jurisdictions and Roles

MODULE 2 :

March 6, 2025 • 1:30–4:30pm EST

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

MODULE 3 : March 11, 2025 • 1:30–4:30pm EST

Recent OFAC Guidance and Risk Mitigation for Your Chinese Operations—and the Impact of China’s Retaliatory Measures

MODULE 4 : March 13, 2025 • 1:30–4:30pm EST

A Complete Primer on EU and UK Sanctions—and the Similarities and Differences with U.S. Restrictions

MODULE 5 : March 18, 2025 • 1:30–4:30pm EST

Deciphering Country-Specific Sanctions: A Roadmap to U.S. Sanctions on Cuba, Iran, North Korea, Syria, the Crimea and so-called Donetsk and Luhansk Regions of Ukraine, and Venezuela

MODULE 6 : March 20, 2025 • 1:30–4:30pm EST

The Essentials of an Effective Global Sanctions Compliance Program: Lessons Learned from Enforcement Actions

MODULE 7: March 25, 2025 • 1:30–4:30pm EST

How to Submit an Application to the OFAC Licensing Division: How to Prepare and Minimize the Risk of Delays and Denials

Professional Development to Help You Succeed on the Job

Your Blueprint to Proficiency: Immersive and Practical

y Interactive format that encourages dialogue with attendees and speakers

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 Quick access to the session recordings, so you can stay on track

Real Life, Not Textbook

y Expert speakers will take you through concrete experiences and “war stories”

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

WHO SHOULD ATTEND?

Vice Presidents, Managers, Specialists and Counsel working in:

y OFAC Compliance

y Global Sanctions

y AML

y Financial Crime

y Regulatory Compliance

y International Trade

y Compliance

y Supply Chain

MODULE 8: March 27, 2025 • 1:30–4:30pm EST

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

Connect: Build Your Network and "Brain Trust"

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

y Develop your sounding board and global network of community peers

y Access a highly respected, diverse faculty with verified subject-matter expertise and track records

y Join dedicated Q&A sessions with expert faculty

Outside Counsel Specializing in

y Economic Sanctions

y OFAC

y International Trade

y Financial Services

y AML and Financial Crime

MEET OUR EXPERT INSTRUCTORS

Government Instructors

Ms. Bridget Van Buren Section Chief, Compliance Division Office of Foreign Assets Control, U.S. Department of the Treasury

Mr. Matt Breznai Licensing Division Office of Foreign Assets Control, U.S. Department of the Treasury

In-House Instructors & Thoughtleaders

Nick Adams Global Trade Manager Post Holdings

Jennifer Downing Managing Director and Senior Counsel BNP Paribas

Dara Fernández General Counsel, Trade Sanctions Honeywell

Glenda Juliano Director, Sanctions Compliance

Raymond James

Jeanette Miller SVP - U.S. Head of Sanctions Regulatory Response & Development, Financial Crime, U.S. Economic Sanctions

HSBC

Ben Namshir Leader, Global Trade Compliance

Cisco

Alexander Parets Senior Director, Head of Enterprise Screening & Sanctions Risk Management Capital One

Nidhi Rao Managing Director BDO

Victor Rotolo Associate Director The Risk Advisory Group

Jake Schostag Director of Global Trade Compliance Watlow

Real-Life Benefits of Attending:

ĉ ADVANCE your career and professional development by becoming proficient in the essentials of Economic Sanctions

ADD VALUE to your organization with a practical roadmap for compliance, screening, licensing and risk management

Law Firm Instructors

Anna Bradshaw Partner (London) Peters & Peters Solicitors LLP (UK)

Anden Chow Partner MoloLamken LLP

Jack Hayes Partner Steptoe LLP

Nathanael Kurcab Of Counsel

Morrison & Foerster LLP

Tal Machnes Counsel

Arnold & Porter Kaye Scholer LLP

Kian Meshkat Principal Attorney Meshkat Law, PC

Sara Nordin Partner (Brussels) White & Case LLP

Danielle Pressler Counsel King & Spalding LLP

Anthony Rapa Partner Blank Rome LLP

DJ Wolff Partner Crowell & Moring LLP

CONNECT with a global community of economic sanctions peers

1:30–4:30 pm EST

Your U.S. Economic Sanctions Roadmap: Key Concepts, Agencies, Jurisdictions and Roles

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?

An 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 more National Security Areas

Secondary Sanctions

• Scope: Menu-based versus Designations

» Application in Practice

» Financial Institution Considerations

Human Rights and Supply Chain Considerations

Alexander Parets

Senior Director, Head of Enterprise Screening & Sanctions Risk Management Capital One

Nick Adams Global Trade Manager Post Holdings

Kian Meshkat

Principal Attorney Meshkat Law, PC

• Sanctions in Context: Forced Labor, 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

Accreditation will be sought in those jurisdictions requested by the registrants which have continuing education requirements. This course is identified as nontransitional for the purposes of CLE accreditation.

ACI certifies this activity has been approved for CLE credit by the New York State Continuing Legal Education Board.

For more information on ACI’s CLE process, visit: www.AmericanConference.com/Accreditation/CLE EARN CLE CREDITS

ACI certifies this activity has been approved for CLE credit by the State Bar of California.

ACI has a dedicated team which processes requests for state approval. Please note that event accreditation varies by state and ACI will make every effort to process your request.

WEEK ONE March 6, 2025 | Module 2

1:30–4:30 pm EST

A

Deep

Overview

Dive

into

the Latest

Russia Sanctions Compliance and Screening Requirements

• Which authorities are implementing Russia-related restrictions

• The evolution of sanctions against Russia 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

• Key Differences across U.S., EU, and UK

» “Transactions” Prohibitions: U.S. & EU

» Limited list-based sanctions: the “sectoral” sanctions program current

“What” Based Restrictions

• Trade Controls: Export & Import Restrictions

• Professional Services Ban

• Investment bans

• Capital market / securities restrictions

• Shipping, Aircraft, and Trucking

Key Compliance Issues & Predictions

Ownership & Control Assessment

• U.S. 50% Rule

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

Export Controls

• Rising expectations on financial institutions (FinCEN Advisory and recent BIS Guidance)

• 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 investation and enforcement as rules stabilize

• Cross-border investigations and cooperation (including U.S.-UK)

Where are we going in 2024

• Anticipated policy and regulatory changes under a new U.S. Administration

• One-way ratchet on restrictions with a long-time frame

• Designations / export controls / restricted services

• Re-risking timeline

• Considerations for remaining in Russia

• Lessons learned for exiting Russia–and the possible roadblocks

Glenda Juliano Director, Sanctions Compliance Raymond James

Victor Rotolo Associate Director The Risk Advisory Group

DJ Wolff Partner

Crowell & Moring LLP

WEEK TWO March 11, 2025 | Module 3

1:30–4:30 pm EST

Recent OFAC Guidance and Risk Mitigation for Your Chinese Operations and the Impact of China’s Retaliatory Measures

The Essentials of U.S. Sanctions on China

• 2005 Section 311 designation of Banco Delta Asia

• DPRK and Iran-related designations of Chinese entities

• Use of Entity List

• Huawei and most non-U.S.-affiliates

• Xinjiang and human rights-related designations, and the interplay with UFLPA

• CMIC sanctions

• Contrasting Biden v. Trump Administration policies

• Limitations on scope

» CMIC-listed entities only

» U.S. facilitation of foreign investments

Chinese Blocking Statute

• Reporting requirement on Chinese companies

• Prohibition on compliance with “foreign law”

• Private right of action

• Identification of “extraterritorial” laws - current status

• Pending identification of “extraterritorial” laws

• Potential for aggressive enforcement compared with the EU

• Chinese Retaliation

China’s Anti-Foreign Sanctions Law

• 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

• New data security law 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

Recent OFAC Guidance

• New and expected guidance -and the impact

• Virtual Currency

• Compliance guidance for instant payments

Jack

WEEK TWO March 13, 2025 | Module 4

1:30–4:30 pm EST

A Complete Primer on EU and UK Sanctions—and the Similarities and Differences with U.S. Restrictions

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 U.S. 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 the EU and UK Sanctions Regimes:

» Asset Freezes and Travel Bans

» “Any Transaction” Prohibition

» Restrictions on SWIFT access for financial institutions

» Investment restrictions

» Oil Price Cap

» Professional services ban

» 11th EU Sanctions Package

• 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 U.S. sanctions

Dara Fernández General Counsel, Trade Sanctions Honeywell

Anna Bradshaw Partner (London) Peters & Peters Solicitors LLP (UK)

Sara Nordin Partner (Brussels) White & Case LLP

The C5 Group, comprising American Conference Institute, the Canadian Institute and C5 in Europe, is a leading global events and business intelligence company.

For over 40 years, C5 Group has provided the opportunities that bring together business leaders, professionals and international experts from around the world to learn, meet, network and make the contacts that create the opportunities. Our conferences and related products connect the power of people with the power of information, a powerful combination for business growth and success.

WEEK THREE March 18, 2025 | Module 5

1:30–4:30 pm EST

Deciphering Country-Specific Sanctions: A Roadmap to U.S. Sanctions on Cuba, Iran, North Korea, Syria, the Crimea and so-called Donetsk and Luhansk Regions of Ukraine, and Venezuela

Iran

• Jurisdictional scope

• Recent developments

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

• Frequently used general licenses and their practical limitations

• Broad array of secondary sanctions authorities

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)

• Broad prohibitions apply to all Cuban nationals

Jennifer Downing Managing Director, Senior Counsel BNP Paribas

Danielle Pressler Counsel

King & Spalding LLP

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

Venezuela

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

• 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

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

• Discussion of key general licenses

Crimea, so-called Donetsk and Luhansk Regions of Ukraine

• Traditional comprehensive trade embargos

• Heightened risk of sanctions circumvention and facilitation

• General licenses with limited scope

With conferences in the United States, Canada, Latin America and Europe, the C5 Group of Companies: American Conference Institute, Canadian Institute, and C5 Group, provides a diverse portfolio of conferences, events and roundtables devoted to providing business intelligence to senior decision makers responding to challenges around the world.

Don’t miss the opportunity to maximize participation or showcase your organization’s services and talent. For more information please contact us at: SponsorInfo@AmericanConference.com

HANDSHAKE Global Sponsorship Opportunities

1:30–4:30 pm EST

The Essentials of an Effective Global Sanctions Compliance Program: Lessons Learned from Enforcement Actions

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 Enforcement Actions, Penalties and Lessons Learned

• Geofencing and IP address blocking

• Counterparty screening, due diligence, and / or compliance procedures

• Leveraging technological tools for sanctions compliance purposes

• Preparing a voluntary self-disclosure

• Remediation and corrective actions

• OFAC’s enforcement guidelines and penalty calculations

• Civil vs. criminal enforcement / liability

• Supply chain due diligence

• Parent and successor liability

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

How Sanctions Enforcement and Disclosures Arise

• Internal investigations and blocking or rejecting reports

• Notices from other parties

• Responding to OFAC subpoenas and requests for information

• Considerations for whether to submit a voluntary self-disclosure

Factors Affecting 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

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.

Ben Namshir Leader, Global Trade Compliance Cisco
Anthony Rapa Partner Blank Rome LLP
Nidhi Rao Managing Director BDO

1:30–4:30 pm EST

How to Submit an Application to the OFAC Licensing Division: How to Prepare and Minimize the Risk of Delays and Denials

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

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?

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

Jeanette Miller SVP - US Head of Sanctions Regulatory Response & Development, Financial Crime, US Economic Sanctions HSBC

Nathanael Kurcab Of Counsel Morrison & Foerster LLP

1:30–4:30 pm EST

Ms. Bridget Van Buren

Section Chief, Compliance Division

Office of Foreign Assets Control

U.S. Department of the Treasury

Mr. Matt Breznai

Licensing Division

Office of Foreign Assets Control

U.S. Department of the Treasury

PART 2: Working with the Regulators and Review of Proficiency Assignment

Anden Chow Partner MoloLamken LLP

Tal Machnes Counsel

Arnold & Porter Kaye Scholer LLP

During the first half of this session, OFAC will give insights into practical guidance on working with the organization.

During the last half, proficiency assignment questions will be reviewed, and participants will gain feedback from instructors. Topics to be discussed include:

• Understanding how OFAC is structured

• The importance of FAQs

• Reporting to OFAC

• Importance of Communication with regulators

• How to best get your questions answered

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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