AGENDA AT-A-GLANCE
PRE-CONFERENCE WORKSHOPS | Tuesday, December 3, 2024
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
8:00 am Networking Breakfast and Registration
8:45 am Opening Remarks from the Co-Chairs
9:00 am OPENING KEYNOTE ADDRESS WITH OFAC Year-in-Review and Enforcement Priorities for 2025
9:30 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
10:30 am Extended Networking Break
11:00 am KEYNOTE INTERVIEW: Bureau of Security and Industry (BIS)
11:30 am RUSSIA-RELATED SANCTIONS, PART 1
Managing Third-Party Risk and Detangling Ownership Structures: Mitigating Secondary Sanctions Risks and Clarifying Requirements Under EO 14114
12:15 pm Networking Luncheon
1:30 pm Managing the Convergence of Economic Sanctions, Export Controls and AML Amid Intensifying Enforcement
2:30 pm Operationalizing AI to Enhance Screening and Reduce the Risk of False Positives
3:15 pm Networking Break
3:30 pm IRAN-RELATED SANCTIONS
Transshipment and Supply Chain Security: Compliance and Consequences for Contributing to Iran and Russia’s UAV Programs
4:15 pm SMALLER-GROUP ROUNDTABLES
Roundtable 1: Russia and China
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
5:00 pm Day 1 Closing Remarks and
WORKSHOP B CLOCK 1:30–5:00 PM
A Step-by-Step Guide to Minimizing Circumvention and Evasion Risks: Upgrading Your Toolbox for Detecting and Addressing Increasingly Sophisticated Schemes
MAIN CONFERENCE DAY 2
Thursday, December 5, 2024 | 8:00 am–4:45 pm 8:00
9:15 am CHINA, PART I: COMPLEX DILEMMAS
Navigating the Newest, Most Complex Dilemmas Related to China: Circumvention, Expanded U.S. Export Controls and Chinese Countermeasures
10:15 am Networking Break
10:30 am FIRESIDE CHAT with Director, Task Force KleptoCapture
11:00 am RUSSIA-RELATED SANCTIONS, PART 2
Navigating the Blocking of the National Settlement Depository (NSD): What it Means for Organizations Operationally
12:00 pm Networking Luncheon
1:15 pm FIRESIDE CHAT: OFSI
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
2024 SPEAKER FACULTY
KEYNOTE S PEAKERS
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
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
Ian C. Richardson
Chief Counsel for Corporate Enforcement, National Security Division
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
INDUSTRY SPEAKERS & THOUGHTLEADERS
Omar AL-Mogahed
Senior Sanctions Investigator Robinhood
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
Standard Chartered Bank
Maeva Donlin
VP, Head of Sanctions Compliance Nordea
Luis Duarte
U.S. Head of OFAC/Sanctions Compliance Generali
Bahman Farahdel
Global Head of Sanctions & Trade Compliance
Bloomberg
Edward Fishman
Senior Research Scholar and Adjunct Professor of International and Public Affairs
Columbia University
Nathan Harsch
Vice President and Chief Compliance Officer
Westinghouse Electric Company
Madina Israilova
Director, Sanctions Compliance UBS
Andrew Jensen
Managing Director, Global Head of Sanctions & ABC TD
Reilly Kimmerling
Senior Director, Global Trade Compliance MACOM
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.
Brian O’Toole
Global Head of Sanctions
Wells Fargo
Robert Patterson
Director, Americas Head of Sanctions Investigations Société Generale
Elizabeth Rosenberg Managing Director, Global Financial Crimes Public Policy Bank of America
Cassie Schock Head of Sanctions Compliance BNP Paribas
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
LAW FIRM SPEAKERS
Andrew C. Adams Partner
Steptoe LLP
Former Director, Task Force KleptoCapture
Andrea Al-Attar
Principal
The Law Office of
Andrea T. Al-Attar, PC
Former Section Chief, Licensing Division, OFAC
Caroline Brown Partner
Crowell & Moring LLP
Anden Chow
Partner MoloLamken LLP
Darshak Dholakia
Partner
Dechert LLP
Rachel Fiorill
Partner
Morrison & Foerster LLP
Peter Harrell
Attorney; Former Senior Director, International Economics and Competitiveness, The White House
National Security Council; National Economic Council
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
Maura Rezendes
Partner and Head of Sanctions
A&O Shearman
Adam M. Smith
Partner
Gibson, Dunn & Crutcher LLP
U.S. Department of Justice
Jenn Cox
Senior Manager, Trade Screening
Microsoft
Jeanette Miller
SVP – US Head of Sanctions
Regulatory Response & Development, Financial Crime, US Economic Sanctions
HSBC Bank USA
Aydin M. Akgün Director of Licensing & Compliance Ferrari & Associates Former Chief, Licensing Division, OFAC
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)
BA Step-by-Step Guide to Minimizing Circumvention and Evasion Risks: 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
Maura Rezendes
Partner and Head of Sanctions
A&O Shearman
Cassie Schock
Head of Sanctions Compliance
BNP Paribas
• 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
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11:00 KEYNOTE INTERVIEW
Matthew Axelrod
Assistant Secretary for Export Enforcement, Bureau of Industry and Security
U.S. Department of Commerce
RUSSIA-RELATED SANCTIONS, PART 1
11:30 Managing
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
Phillip Byrnes Global Deputy Head, Sanctions & Global Head, Sanctions Advisory, Financial Crime Compliance Standard Chartered Bank Richard McDermott Global Sanctions Program Director AmTrust Financial Services, Inc.
• Including specific clauses in contracts with third parties that mandate compliance with EO 14114 and allowing for termination in case of violations
12:15 Networking Luncheon
“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
1:30 Managing the Convergence of Economic Sanctions, Export Controls and AML Amid Intensifying Enforcement
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
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
Bing Xu
Chief Counsel, Global Trade Controls, Regional Head of Sanctions and Export Control – North America and Asia-Pacific Rolls-Royce
Andrew C. Adams Partner
Steptoe LLP
Former Director, Task Force KleptoCapture
2:30 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
• Dissecting the lengths and limits of AI capabilities—and when other technologies and/or manual reviews still remain key
3:15 Networking Break
Media Partners:
Jenn Cox Senior Manager, Trade Screening Microsoft
Luis Duarte
U.S. Head of OFAC/Sanctions Compliance Generali
Nathan Harsch
Vice President and Chief Compliance Officer Westinghouse Electric Company
3:30 Transshipment and Supply Chain Security: New 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
4:15 SMALLER-GROUP ROUNDTABLES
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
5:00 Day 1 Closing Remarks and Networking Cocktail Reception
ROUNDTABLE 2: Venezuela Exploring the Latest Updates to Venezuela-Related Sanctions— What’s Ahead
Malissa Lewis
Director, Head of Sanctions Advisory (America) Société Generale
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)
Brian O’Toole
Global Head of Sanctions
Wells Fargo
•
11:00 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
• 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
Brandon Smith Director, Americas Head of Sanctions and Anti-Bribery Corruption (ABC) Barclays
Madina Israilova Director, Sanctions Compliance UBS 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
2:30 Conducting Detailed Risk Assessments Related to Your Operations and Business in China: Revisiting Investments, Supply Chain Dependency, and Identifying Areas for Strategic
• 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
• Adjusting your investment portfolio by reallocating assets away from high-risk sectors in China to more stable markets
Adjustments
George Ioannidis Acting Deputy Special Agent in Charge
Homeland Security Investigations
Clay Stevenson Managing Director, Global Head of Sanctions & Embargoes Deutsche Bank
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
Heather Jacobson Deputy Director, Office of Economic Sanctions Policy and Implementation Bureau of Economic and Business Affairs
U.S. Department of State
Nathanael Kurcab Of Counsel
Morrison & Foerster LLP
Jeanette Miller SVP – US Head of Sanctions Regulatory Response & Development, Financial Crime, US Economic Sanctions HSBC Bank USA
Aydin M. Akgün Director of Licensing & Compliance Ferrari & Associates
Former Chief, Licensing Division, OFAC
Darshak Dholakia Partner Dechert LLP
4:15 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 Closing Remarks from the Co-Chairs and Conference Concludes
Adam M. Smith
Partner
Gibson, Dunn & Crutcher LLP
Philip Smith
Group Head of Financial Crime Risk Management
Booking Holdings
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