14th New York Forum on Economic Sanctions - DS

Page 1


Molly Moeser

Chief, Money Laundering and Asset Recovery Section

U.S. Department of Justice

Ian C. Richardson

Chief Counsel for Corporate Enforcement, National Security Division

U.S. Department of Justice

Tara La Morte Chief, Illicit Finance & Money Laundering Unit, Asset Forfeiture Coordinator U.S. Attorney’s Office Southern District of New York

Heather Jacobson

Joshua Jungman

Policy Chief, Compliance DivisionU.S. Office of Foreign Assets Control (OFAC) U.S. Department of the Treasury

Michael Khoo Director, Task Force KleptoCapture U.S. Department of Justice

Matthew Axelrod

Assistant Secretary for Export Enforcement, Bureau of Industry and Security U.S. Department of Commerce

Alina Nedea Head of Sanctions Unit, DG FISMA European Commission

Giles Thomson Director Office for Financial Sanctions Implementation (OFSI) and Economic Crime HM Treasury

Agent in Charge Homeland Security Investigations

Deputy Director, Office of Economic Sanctions Policy and Implementation Bureau of Economic and Business Affairs, U.S. Department of State

AGENDA AT-A-GLANCE

OFAC Sanctions Compliance Deep Dive: Blueprint to Maintaining a Highly Effective Sanctions Compliance Program and Satisfying OFAC Requirements

MAIN CONFERENCE DAY 1

Wednesday, December 4, 2024 | 8:00 am–5:00 pm

7:30 am Networking Breakfast and Registration

8:30 am Opening Remarks from the Co-Chairs

8:45 am SPECIAL POST-ELECTION SESSION

Preparing for the Post-Election Aftermath: Repositioning Your Economic Sanctions and Export Compliance Programs to Prepare for a New Administration

9:45 am RUSSIA-RELATED SANCTIONS, PART 1

Managing Third-Party Risk and Detangling Ownership Structures: Mitigating Secondary Sanctions Risks and Clarifying Requirements Under EO 14114

10:30 am Extended Networking Break

10:45 am KEYNOTE INTERVIEW: Bureau of Security and Industry (BIS)

11:30 am Operationalizing AI to Enhance Screening and Reduce the Risk of False Positives

12:15 pm Networking Luncheon

1:15 pm OPENING KEYNOTE ADDRESS WITH OFAC Year-in-Review and Enforcement Priorities for 2025

2:00 pm Managing the Convergence of Economic Sanctions, Export Controls and AML Amid Intensifying Enforcement

3:00 pm Networking Break

3:15 pm IRAN-RELATED SANCTIONS

Transshipment and Supply Chain Security: Compliance and Consequences for Contributing to Iran and Russia’s

Roundtable 1: Russia and

Tackling the Due-Diligence Challenges

Roundtable 2: Venezuela

Analyzing the Latest Updates to Venezuela-Related Sanctions

Roundtable 3: Responding to an OFAC Subpoena Do’s and Don’ts

Roundtable 4: FinTech and the Future of Sanctions How FinTech is Helping Organizations Identify and Mitigate AIS Spoofing and Other Convoluted Schemes

Strengthening your Risk-Based Approach to Sanctions Evasion: Upgrading Your Toolbox for Detecting and Addressing Increasingly Sophisticated Schemes

MAIN CONFERENCE DAY 2

Thursday, December 5, 2024 | 8:00 am–4:45 pm

8:30 am Opening Remarks from the Co-Chairs

8:40 am KEYNOTE: THE EU COMMISSION

9:10 am CHINA, PART I: COMPLEX DILEMMAS

Navigating the Newest, Most Complex Dilemmas Related to China: Circumvention, Expanded U.S. Export Controls and Chinese Countermeasures

9:55 am Networking Break

10:10 am FIRESIDE CHAT with Director, Task Force KleptoCapture

10:45 am RUSSIA-RELATED SANCTIONS, PART 2

Navigating the Blocking of the National Settlement Depository (NSD): What it Means for Organizations Operationally

11:30 am FIRESIDE CHAT: OFSI

12:00 pm Networking Luncheon

1:00 pm Strengthening Your Risk-Based Approach to Sanctions Evasion: Strategies for Identifying and Combatting the Newest, Most Complex Schemes

1:45 pm Responding to Concurrent Sanctions and Export Enforcement Actions, and Best Practices for Voluntary Self-Disclosures

2:30 pm CHINA, PART 2: RISK ASSESSMENTS

Conducting Detailed Risk Assessments for Your Operations and Business in China: Revisiting Investments, Supply Chain Dependency, and Identifying Strategic Adjustments

3:15 pm Networking Break

3:30 pm Keeping Up with New U.S. Sanctions Designations and Delistings: How to Know If Your Program is Adapting and Integrating Rapid Changes

4:15 pm Human Rights and Forced Labor: Incorporating UFLPA, Global Magnitsky and Targeted Sanctions into Your Compliance Strategy

5:00 pm Closing Remarks from the Co-Chairs and Conference Concludes

SPEAKER FACULTY

KEYNOTE S PEAKERS

Joshua Jungman

Policy Chief, Compliance Division

Office of Foreign Assets Control (OFAC), U.S. Department of the Treasury

Matthew Axelrod

Assistant Secretary for Export Enforcement, Bureau of Industry and Security

U.S. Department of Commerce

Michael Khoo

Director, Task Force KleptoCapture

U.S. Department of Justice

Alina Nedea

Head of Sanctions Unit, DG FISMA European Commission

Giles Thomson Director

Office for Financial Sanctions Implementation (OFSI) and Economic Crime HM Treasury

CONFERENCE CO-CHAIRS

Chanhee Han

Senior Director, Legal Counsel, International Trade and Sanctions The Coca Cola Company

Nicole Jacoby

Senior Vice President & Head of Compliance, Americas Christie’s

Jason Prince Partner

Akin Gump Strauss Hauer & Feld LLP

Immediate-Past OFAC Chief Counsel

SENIOR GOVERNMENT OFFICIALS

Molly Moeser

Chief, Money Laundering and Asset Recovery Section

U.S. Department of Justice

Michael P. Grady

Chief, Bank Integrity Unit, Money Laundering & Asset Recovery Section

U.S. Department of Justice, Criminal Division

Heather Jacobson

Deputy Director, Office of Economic Sanctions Policy and Implementation Bureau of Economic and Business Affairs, U.S. Department of State

Tara La Morte

Chief, Illicit Finance & Money Laundering Unit, Asset Forfeiture Coordinator, U.S. Attorney’s Office Southern District of New York

Dan Clutch

Deputy Director, Office of Export Enforcement (OEE) Bureau of Industry and Security (BIS)

U.S. Department of Commerce

George Ioannidis

Acting Deputy Special Agent in Charge Homeland Security Investigations

Brad Brooks-Rubin

Senior Advisor

U.S. Department of State

INDUSTRY SPEAKERS & THOUGHTLEADERS

Omar AL-Mogahed

Senior Sanctions Investigator Robinhood

Sara Donovan

Head of Sanctions Compliance

Morgan Stanley

Maeva Donlin

VP, Head of Sanctions Compliance Nordea

Brian Gatta

Senior Counsel

Akin Gump Strauss Hauer & Feld LLP

Co-Founder and Sanctions

Module Lead

OverRuled, powered by Akin

Mac Fadlallah Partner

Akin Gump Strauss Hauer & Feld LLP

Co-Founder

OverRuled, powered by Akin

Claire Axinn

Director, Sanctions and Risk Advisory Capital One WSN Member

Sahand Boorboor

Global Head of Financial Crimes Compliance Citadel Securities

Phillip Byrnes

Global Deputy Head, Sanctions & Global Head, Sanctions Advisory, Financial Crime Compliance

David Y. Lee

Global Director for Sanctions & Screening and OFAC Officer Payoneer

Malissa Lewis Director, Head of Sanctions Advisory (America) Société Generale Corporate and Investment Banking

David Lynch SVP, Analytical Solutions Sayari

Richard McDermott

Global Sanctions Program Director AmTrust Financial Services, Inc.

Andrew C. Adams

Partner

Steptoe LLP

Former Director, Task Force KleptoCapture

Aydin M. Akgün

Director of Licensing & Compliance

Ferrari & Associates

Former Chief, Licensing Division, OFAC

Andrea Al-Attar Principal

The Law Office of Andrea T. Al-Attar, PC

Bahman Farahdel

Global Head of Sanctions & Trade Compliance Bloomberg

Edward Fishman

Senior Research Scholar and Adjunct Professor of International and Public Affairs Columbia University

Justyna Gudzowska

Senior Policy & Development Advisor The Sentry

Nathan Harsch

Vice President and Chief Compliance Officer Westinghouse Electric Company

Madina Israilova Director, Sanctions Compliance UBS

Ian C. Richardson

Chief Counsel for Corporate Enforcement, National Security Division

U.S. Department of Justice

Standard Chartered Bank

Jenn Cox

Senior Manager, Trade Screening

Microsoft

Andrew Jensen

Managing Director, Global Head of Sanctions & ABC TD

Reilly Kimmerling

Senior Director, Global Trade Compliance MACOM

Shane Krumeich Director, Trade Compliance Department Mitsubishi Corporation (Americas)

Brandon Lee

Vice President, Government Sanctions Group Goldman Sachs

Robert Patterson

Director, Americas Head of Sanctions Investigations Société Generale

Elizabeth Rosenberg

Managing Director, Global Financial Crimes Public Policy Bank of America

Cassie Schock

Director, Head of Sanctions CIB Americas BNP Paribas

Ilya Shulman

Executive Director, Global Financial Crimes Counsel, Head of Sanctions Legal JPMorgan Chase & Co.

Brandon Smith

Director, Americas Head of Sanctions and Anti-Bribery Corruption (ABC) Barclays

Philip Smith Group Head of Financial Crime Risk Management Booking Holdings

Clay Stevenson

Managing Director, Global Head of Sanctions & Embargoes Deutsche Bank

Tory Tibor VP, Global Head of Trade Compliance; and Economic Sanctions Compliance Officer Olympus Corporation

Bing Xu

Chief Counsel, Global Trade Controls, Regional Head of Sanctions and Export Control –North America and Asia-Pacific Rolls-Royce

Former Section Chief, Licensing Division, OFAC

Caroline Brown Partner

Crowell & Moring LLP

Stephanie Brown Cripps Partner

Freshfields US LLP

Kuang Chiang Counsel

A&O Shearman

Anden Chow

Partner

MoloLamken LLP

Darshak Dholakia Partner Dechert LLP

Rachel Fiorill Partner

Morrison & Foerster LLP

Nathanael Kurcab Of Counsel

Morrison & Foerster LLP

David H. Lim

Partner

White & Case LLP

Former Co-Director, Task Force KleptoCapture

Sara Nordin

Partner (Brussels, Stockholm) White & Case LLP WSN Member

Adam M. Smith

Partner

Gibson, Dunn & Crutcher LLP

Nicole Succar Partner

Paul, Weiss, Rifkind, Wharton & Garrison LLP

Pre-Conference Workshops

Tuesday, December 3, 2024

9:00 am–12:30 pm (Registration at 8:30 am)

AOFAC Sanctions Compliance Deep Dive: A Complete Blueprint to Maintaining an Effective, Agile Sanctions Compliance Program and Satisfying OFAC Requirements

With so many rapid changes, it is crucial to ensure that your program can quickly and effectively pivot accordingly. During this deep-dive intensive, practical workshop, the speakers will walk through an updated blueprint that can serve as invaluable resource for how to strengthen your program and position it for more anticipated developments and risk factors.

Topics will include:

• Conducting thorough risk assessments to identify your organization’s exposure to OFAC sanctions risks, and regularly updating the risk assessment to reflect changes in business operations, geopolitical dynamics, and updates to sanctions lists

• Developing and implementing comprehensive policies and procedures that align with OFAC regulations and ensuring they are tailored to your organization’s specific risk profile

• Updating screening procedures for customers, vendors, and transactions against OFAC’s sanctions lists, including Specially Designated Nationals (SDN) and Blocked Persons List

• Establishing systems for monitoring transactions in real-time to detect potential sanctions violations and leveraging emerging technologies for supply chain transparency

Reilly Kimmerling Senior Director, Global Trade Compliance MACOM

Anden Chow Partner MoloLamken LLP

Robert Patterson

Director, Americas Head of Sanctions Investigations Société Generale

• Regularly testing and auditing your compliance program to ensure effectiveness and adherence to OFAC requirements, including internal audits and third-party audits

1:30–5:00 pm (Registration at 1:00 pm)

BStrengthening your Risk-Based Approach to Sanctions Evasion: Upgrading Your Toolbox for Detecting and Addressing Increasingly Sophisticated Schemes

Circumvention and evasion schemes have become increasingly sophisticated, posing significant enforcement and compliance risks. As detection and prevention are becoming more complex than ever before, staying on top of the most effective strategies is key— from continuous monitoring, the implementation of robust due diligence practices and more.

During this comprehensive, deep-dive workshop, we will review a fully updated, step-by-step approach to identifying and addressing circumvention and evasion schemes and what to do when uncovering an actual or suspected issue.

Topics will include:

• Strengthening your risk-based approach to sanctions evasion, and strategies for identifying and combatting the newest, most complex schemes

• Dissecting the most sophisticated and emerging, new schemes. and how they were uncovered

• Various methods used in circumvention schemes, such as mislabeling, transshipment, and undervaluation of goods

Cassie Schock

Director, Head of Sanctions CIB Americas BNP Paribas

Shane Krumeich

Director, Trade Compliance Department Mitsubish Corporation (Americas)

• Implementing AI and other advanced monitoring tools: Best practices for continuously monitoring transactions and supply chains for red flags and irregularities

• Strengthening due diligence processes by conducting thorough background checks on suppliers and partners, and regularly auditing compliance practices

• How to know if your detection strategies are relevant and effective

• Promoting a strong compliance culture within your organization through regular training and awareness programs, encouraging employees to report suspicious activities

Day One

Wednesday, December 4, 2024

7:30 Networking Breakfast and Registration

8:30 Opening Remarks from the Co-Chairs

Chanhee Han

Senior Director, Legal Counsel, International Trade and Sanctions The Coca Cola Company

Nicole Jacoby

Senior Vice President & Head of Compliance, Americas Christie’s

Jason Prince Partner

Akin Gump Strauss Hauer & Feld LLP

Immediate-Past OFAC Chief Counsel

8:45 Preparing for the Post-Election Aftermath: Repositioning Your Economic Sanctions and Export Compliance Programs to Prepare for a New Administration

Join us for a special opening panel discussion focused on the outlook of sanctions and export controls on the heels of the 2024 U.S. Presidential election. As a new administration takes office in January, organizations must be ready to proactively reposition their programs to anticipate potential changes in policies and enforcement priorities, ensuring readiness for any scenario.

Key topics will include:

• Anticipated policy and enforcement shifts, and the impact on your organization’s risk profile

• Unpacking various scenarios that could arise from potential shifts in sanctions focus

• Creating contingency plans to address anticipated changes effectively

• Leveraging sophisticated compliance tools and technologies for real-time monitoring, automated screening, and enhanced response capabilities to swiftly adapt to new sanctions designations and real-time regulatory changes

• Strengthening risk mitigation tactics and resilience in the face of geopolitical uncertainty—impacts of a new administration

• Managing sanctions hot spots in 2025 and beyond

Sahand Boorboor

Global Head of Financial Crimes Compliance Citadel Securities

Edward Fishman

Senior Research Scholar and Adjunct Professor of International and Public Affairs

Columbia University

Former Russia Sanctions Lead, U.S. Department of State

David H. Lim Partner White & Case LLP

Former Co-Director, Task Force KleptoCapture

Elizabeth Rosenberg

Managing Director, Global Financial Crimes Public Policy Bank of America

George Ioannidis Acting Deputy Special Agent in Charge

Homeland Security Investigations

Third-Party Risk and Detangling Ownership Structures: Mitigating Secondary Sanctions Risks and Clarifying Requirements Under EO 14114

Executive Order (EO) 14114 highlights the critical need for companies to manage third-party risks and detangle complex ownership structures to avoid secondary sanctions. In today’s interconnected global economy, hidden ties to sanctioned individuals or entities can expose businesses to significant risks. EO 14114 mandates that organizations enhance their compliance programs, conduct thorough due diligence, and ensure transparency in ownership to navigate these challenges and avoid inadvertent violations.

During this panel, we will explore:

• Implementing comprehensive due diligence procedures to assess third-party relationships, including in-depth checks on ownership structures and connections to sanctioned entities

• Establishing a system for ongoing monitoring of third-party ownership and control changes to quickly identify and address any emerging sanctions risks

• Revising sanctions compliance policies to reflect EO 14114 requirements, ensuring they are communicated across your organization and to relevant third parties

• Including specific clauses in contracts with third parties that mandate compliance with EO 14114 and allowing for termination in case of violations

“Quality content, came away feeling like it was a good use of my time, good venue, good food and drinks. ACI staff were very helpful and friendly.” SVP & ASSOCIATE GENERAL COUNSEL, THE CLEARING HOUSE
Rachel Fiorill Partner
Morrison & Foerster LLP
David Lynch
SVP, Analytical Solutions Sayari

11:30 Operationalizing AI to Enhance Screening and Reduce the Risk of False Positives

AI may offer a transformative approach to sanctions compliance by strengthening customer due diligence and reducing false positives. By leveraging advanced machine learning algorithms and natural language processing, organizations can analyze vast amounts of data with greater accuracy and speed than traditional methods. This could result in, enhanced identification of sanctioned entities and activities, and more efficiency and effectiveness of compliance programs.

During this panel, we will explore the lengths and limits of AI, including key issues:

• To what extent AI can enhance accuracy, efficiency, and adaptability in a complex landscape of multijurisdictional regulatory requirements

• Leveraging AI to reduce false positives

• Strengthening Customer Due Diligence through your AI toolkit

• How organizations are using advanced AI technologies to analyze and process large datasets

• Leveraging automation capabilities of GenAI to streamline the compliance process

Jenn

Nathan Harsch Vice President and Chief Compliance Officer

• Dissecting the lengths and limits of AI capabilities—and when other technologies and/or manual reviews still remain key

2:00 Managing the Convergence of Economic Sanctions, Export Controls and AML Amid Intensifying

The evolving interplay between U.S. economic sanctions, export controls, and AML underscores the pressing need to implement comprehensive risk management practices and upgraded compliance strategies.

During this panel, we will explore:

• How, and why, we are seeing an increased convergence of sanctions, export controls and AML, and what this means for risk and compliance moving forward

• How sanctions, export and AML enforcement agencies are coordinating efforts-and when one enforcement action can lead to more

• Developing and implementing robust compliance strategies that integrate economic sanctions, export controls, and AML

• Leveraging existing resources to maximize compliance in each area

• Conducting regular risk assessments to identify and mitigate overlapping risk factors

Enforcement

Michael P. Grady Chief, Bank Integrity Unit Money Laundering & Asset Recovery Section

U.S. Department of Justice, Criminal Division

Ian C. Richardson Chief Counsel for Corporate Enforcement, National Security Division

U.S. Department of Justice

Justyna Gudzowska

Senior Policy & Development Advisor

The Sentry

and Supply Chain Security:

Compliance Risks Related to Iran and Russia’s UAV Programs – and More

Transshipment and supply chain security have become critical concerns, especially regarding the enforcement of sanctions and export controls related to Iran and Russia’s unmanned aerial vehicle (UAV) programs. The proliferation of UAVs has heightened global security risks, and the U.S. has taken steps to curb the involvement of any entities that contribute to these programs.

During this panel, we will explore:

• Exploring U.S. secondary sanctions with respect to Iran

• Monitoring high-risk transshipment hubs and applying extra scrutiny to prevent diversion and sanctioned destinations

• Integrating geo-fencing capabilities in logistics systems to flag or block shipments destined for high-risk regions associated with sanctions violations

• Ensuring your ERP/trade management systems are integrated with updated global sanctions databases, enabling immediate alerts for any potential violations

• Identifying and controlling the export of dual-use items

Ilya Shulman

Executive Director, Global Financial Crimes Counsel, Head of Sanctions Legal JPMorgan Chase & Co.

Moderator: Andrew C. Adams Partner

Steptoe LLP

Former Director, Task Force KleptoCapture

Brad Brooks-Rubin Senior Advisor
Department of State
Kuang Chiang Counsel
A&O Shearman

Brian Gatta

Senior Counsel

Akin Gump Strauss Hauer & Feld LLP

Co-Founder and Sanctions Module Lead

OverRuled, powered by Akin

Mac Fadlallah Partner

Akin Gump Strauss Hauer & Feld LLP

Co-Founder

OverRuled, powered by Akin

Benefit from smaller-group discussion and networking by selecting the roundtable of your choice:

ROUNDTABLE 1: Russia and China

Tackling Due-Diligence Challenges Related to Russia and China

Maeva Donlin

VP, Head of Sanctions Compliance Nordea WSN Member

Tory Tibor

Vice President, Global Head of Trade Compliance; and Economic Sanctions Compliance Officer

Olympus Corporation

ROUNDTABLE 3: Responding to an OFAC Subpoena

Do’s and Don’ts for Responding to an OFAC Subpoena

Andrea Al-Attar

Principal

The Law Office of Andrea T.

Al-Attar, PC

Former Section Chief, Licensing Division, OFAC

David H. Lim Partner

White & Case LLP

Former Co-Director, Task Force KleptoCapture

ROUNDTABLE 2: Venezuela

Exploring the Latest Updates to Venezuela-Related Sanctions— What’s Ahead

Malissa Lewis Director, Head of Sanctions Advisory (America)

Société Generale

Brandon Lee

Executive Director, Government Sanctions Group Goldman Sachs

ROUNDTABLE 4: FinTech and the Future of Sanctions How FinTech is Helping Organizations Identify and Mitigate AIS Spoofing and Other Convoluted Schemes

David Y. Lee

Global Director for Sanctions & Screening and OFAC Officer Payoneer

Former Deputy Political Counselor, Head of Strategic Affairs and Sanctions Director, U.S. Mission to the United Nations (USUN)

Andrew Jensen

Managing Director, Global Head of Sanctions & ABC TD

Chanhee

by evasion strategies

• Addressing the U.S.-China

Chanhee

10:10 KEYNOTE FIRESIDE CHAT: Task Force KleptoCapture

Michael Khoo Director, Task Force KleptoCapture U.S. Department of Justice

RUSSIA-RELATED SANCTIONS, PART 2

Two

Moderator: Caroline Brown Partner Crowell & Moring LLP

10:45 Navigating the Blocking of the National Settlement Depository (NSD): What it Means for Organizations Operationally

Navigating the blocking of Russia’s National Settlement Depository (NSD) under Russia-related sanctions poses significant operational challenges for organizations, particularly those involved in financial markets, investment, and trade with Russian entities. The NSD is a key component of Russia’s financial infrastructure, acting as the central securities depository for Russian bonds, equities, and other financial instruments. When sanctioned, the operational impact on organizations can be profound, requiring careful navigation and strategic adjustments.

During this panel, we will explore:

• Conducting a comprehensive review of your organization’s exposure to Russian securities held via the NSD and reallocating assets to non-Russian custodians to mitigate the risk of asset freezes

• Identifying and establishing alternative clearing and settlement arrangements outside of the NSD to ensure continuity in trade execution and settlement processes

• Updating your sanctions compliance program to include rigorous screening of all transactions and counterparties for ties to the NSD

• Continuously tracking and adapting to evolving sanctions regulations related to Russia

11:30 KEYNOTE: OFSI

Giles Thomson Director Office for Financial Sanctions Implementation (OFSI) and Economic Crime HM Treasury

Brandon Smith Director, Americas Head of Sanctions and Anti-Bribery Corruption (ABC) Barclays

Madina Israilova Director, Sanctions Compliance UBS

Moderator: Jason Prince Partner

Akin Gump Strauss Hauer & Feld LLP Immediate-Past OFAC Chief Counsel

12:00 Networking Luncheon

1:00

Your Risk-Based Approach to Sanctions Evasion: Strategies for Identifying and Combatting the Newest, Most Complex Schemes

Tara La Morte Chief, Illicit Finance & Money Laundering Unit

Asset Forfeiture Coordinator, U.S. Attorney’s Office Southern District of New York

Molly Moeser Chief, Money Laundering and Asset Recovery Section

U.S. Department of Justice

Bahman Farahdel Director, Sanctions and Risk Advisory Capital One

1:45 Responding to Concurrent Sanctions and Export Enforcement Actions, Including Best Practices for Voluntary Self-Disclosures

In an increasingly complex regulatory environment, organizations face the dual challenge of navigating concurrent sanctions and export enforcement actions while ensuring compliance with evolving laws and regulations. The interplay between these enforcement areas requires a nuanced approach, particularly when it comes to voluntary self-disclosures. During this panel, we will explore:

• Implementing robust internal monitoring systems to detect potential violations

• Determining when to disclose an actual or suspected violation

• Creating a clear protocol for voluntary self-disclosures, including guidelines on when and how to report violations, key personnel responsible for disclosures, and required documentation

• Conducting thorough internal investigations

• Investing in continuous training programs to ensure employees are aware of the latest regulatory requirements and equipped to handle compliance challenges effectively

• Engaging with enforcement authorities: Concrete examples of effective cooperation

CHINA, PART 2

Dan Clutch Deputy Director, Office of Export Enforcement (OEE) Bureau of Industry and Security (BIS) U.S. Department of Commerce

Claire Axinn Director, Sanctions and Risk Advisory Capital One WSN Member

2:30 Conducting Detailed Risk Assessments Related to Your Operations and Business in China: Revisiting Investments, Supply Chain Dependency, and Identifying Areas for Strategic Adjustments

Conducting detailed risk assessments to evaluate potential exposure to China-related investments is essential for organizations to identify vulnerabilities and make strategic adjustments that safeguard their interests in an increasingly complex global environment. During this panel, we will explore:

• Creating a comprehensive map of all business, investments, supply chains, and partnerships tied to China to identify potential vulnerabilities

• Re-assessing business and investment-related risks and potential exposure

• Revisiting supply chain risks and structure

• Overcoming challenges to reducing dependency on China: Diversifying suppliers and production facilities across multiple regions to mitigate disruption risks

• Enhancing compliance protocols to ensure alignment with both Chinese regulations and international sanctions

Laurence Hull Senior Counsel, Global Trade - Legal and Compliance Applied Materials

• Adjusting your investment portfolio by reallocating assets away from high-risk sectors in China to more stable markets

Clay Stevenson Managing Director, Global Head of Sanctions & Embargoes Deutsche Bank

Sara Nordin Partner (Brussels, Stockholm) White & Case LLP
Moderator: Darshak Dholakia Partner Dechert LLP
Moderator: Stephanie Brown Cripps Partner Freshfields US LLP

3:30

Keeping Up with New U.S. Sanctions Designations and Delistings: How to Know If Your Program is Adapting and Integrating Rapid Changes

As OFAC regularly updates its list of sanctioned entities and individuals, the implications for businesses can be significant, affecting everything from supply chains to financial transactions. Navigating these changes requires a nuanced understanding of the regulations and a proactive approach to compliance, ensuring that your organization can adapt swiftly.

During this panel, we will explore:

• Implementing automated systems to receive instant notifications about new OFAC sanctions designations and delistings to stay informed of regulatory changes in real-time

• Creating and maintaining a contingency plan for rapid response to unexpected changes in OFAC sanctions, including protocols for handling immediate compliance issues

• Navigating OFAC’s new “unblocking reporting”

• Utilizing advanced data analytics and machine learning tools to enhance the detection and monitoring of transactions and relationships that may involve newly sanctioned entities

4:15

Deputy Director, Office of Economic Sanctions Policy and Implementation Bureau of Economic and Business Affairs U.S. Department of State

Omar AL-Mogahed Senior Sanctions Investigator Robinhood

Human Rights and Forced Labor: Incorporating UFLPA, Global Magnitsky and Targeted Sanctions into Your Compliance Strategy

The Global Magnitsky Act imposes sanctions on individuals and entities involved in serious human rights abuses and corruption worldwide, while the Uyghur Forced Labor Prevention Act (UFLPA) targets entities implicated in forced labor practices within China’s Xinjiang region.

During this panel, we will explore key issues, including:

• Performing thorough audits to identify and address any links to forced labor in Xinjiang and ensuring transparency in your supply chains

• Adjusting your compliance programs to incorporate the Global Magnitsky Act and the UFLPA

• Implementing systems for real-time monitoring of new Global Magnitsky designations and UFLPA-related updates to ensure ongoing compliance

• Leveraging advanced technologies to improve supply chain traceability and verify that products are not associated with forced labor practices 5:00

“I very much liked the diversity of speakers to hear the issues that they face.” “Very collaborative and open discussion.”
CHIEF COMPLIANCE OFFICER, BANK NEGARA

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