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
Country-Specific Sanctions: A Roadmap to U.S. Sanctions on Iran, Cuba, 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
MODULE 8: March 27, 2025 • 1:30–4:30pm EST Review of Proficiency Assignment and Q&A: Working with the Regulators
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
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
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
Patrick Kelkar Deputy CEO & Managing Director RiskAdvisory
Osvaldo Lee Deputy Global Head of Sanctions Compliance
Bloomberg LP
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
Jake Schostag Director of Global Trade Compliance Watlow
Howard Spieler Business Sanctions Risk Officer, Banking and International Citi
Real-Life Benefits of Attending:
ADVANCE your career and professional development by becoming proficient in the essentials of Economic Sanctions
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
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
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 Dive into the Latest Russia Sanctions
Overview
• Which authorities are implementing Russia-related restrictions
Compliance and Screening Requirements
• The evolution of sanctions against Russia and what is on the horizon
• Lessons learned for exiting Russia–and the possible roadblocks
Glenda Juliano Director, Sanctions Compliance Raymond James
Patrick Kelkar Deputy CEO & Managing Director RiskAdvisory
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
Hayes Partner Steptoe LLP
Jake Schostag Director of Global Trade Compliance Watlow
• 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
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
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.
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WEEK THREE March 18, 2025 | Module 5
1:30–4:30 pm EST
Country-Specific Sanctions: A Roadmap to U.S. Sanctions on Iran, Cuba, and Venezuela
Russia
• Evolving sanctions and objectives of the program
• SDN Designations and “oligarch” sanctions
• Explaining the Directives
• “New investment” ban
• Recent enforcement trends
Iran
• Jurisdictional scope
• Impact of recent developments
• Evolution of the U.S. embargo since JCPOA withdrawal
• 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
Jennifer Downing
Managing Director, Senior Counsel BNP Paribas
Danielle Pressler Counsel
King & Spalding LLP
Osvaldo Lee
Deputy Global Head of Sanctions Compliance Bloomberg LP
• 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
• General licenses allowing dealings with Cuban nationals permanently residing outside of Cuba
• Navigating conflicts of law: U.S. sanctions v. foreign blocking statutes
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, including broad authorizations for CITGO-related transactions and Chevron operations
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.
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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
WEEK FOUR March 25, 2025 | Module 7
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
WEEK FOUR March 27, 2025 | Module 8
Nathanael Kurcab Of Counsel Morrison & Foerster LLP 1:30–4:30
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, the expert instructors will walk you through each question and provide detailed answers. Ample time will be left for Q&A!
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
• The importance of FAQs
• Reporting to OFAC, OFSI, and the EU Commission
• Importance of Communication with regulators
• How to best get your questions answered
Award of “Passport to Proficiency”
Howard Spieler
Business Sanctions Risk Officer, Banking and International Citi
Anden Chow Partner MoloLamken LLP
Participants who have completed all modules will receive a certificate reflecting their proficiency in the essentials of Economic Sanctions
