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Financial Sanctions Compliance: The Critical Role of Administrative Directors

A recent report highlights the importance of administrative directors at each unit, branch, or division in ensuring the accuracy of financial sanctions compliance programs.

Monitoring Compliance

According to the report, the director of the compliance department is responsible for conducting regular monitoring checks on all units and divisions to verify the accuracy of the results. These checks are crucial in identifying potential breaches of international financial sanctions.

• Conducting regular monitoring checks on all units and divisions
• Verifying the accuracy of the results
• Identifying potential breaches of international financial sanctions

The report also emphasizes the importance of inspection tours to all units of the bank, as well as the submission of periodic reports by market risk and operations units to the risk committee. The compliance department is responsible for submitting the results of these checks to the money laundering and terrorism financing risk profile, as well as to the compliance committee.

Awareness and Training

The compliance department is also responsible for organizing periodic training courses to raise awareness among employees about the importance of complying with international economic sanctions. The training sessions cover topics such as:

• The concept of international economic sanctions

• The role of international committees in issuing sanctions

• The risk of breaching these sanctions

• All training records must be archived for at least five years, including:

  • Names of trainees
  • Trainers
  • Training materials
  • Dates and locations of training programs

Record Keeping

The compliance department is responsible for keeping records of all documents, reports, and investigations related to financial sanctions compliance programs. These records must include:

• Notification and reporting procedures to competent authorities and bodies
• Relevant correspondences

Policy Review and Approval

The compliance department is responsible for annually reviewing the international sanction compliance policy and submitting any necessary amendments to the Board of Directors for approval.

• The Board of Directors, represented by the competent committees, is responsible for approving the policy and making any necessary changes
• In the event of a conflict between local laws and regulations in foreign branches or subsidiaries, the stricter instructions shall apply
• Foreign branches and subsidiaries are entitled to create their own policies that emanate from this master policy and comply with local laws

Coordination

The compliance department at each unit, branch, or division must coordinate regularly with the compliance department at headquarters to ensure consistency in implementing the international sanctions compliance program.

In conclusion, the administrative director of each unit, branch, or division plays a crucial role in ensuring the accuracy of financial sanctions compliance programs. Their responsibilities include conducting regular monitoring checks, submitting periodic reports, and organizing training sessions for employees. The report emphasizes the importance of record keeping and policy review and approval to ensure compliance with international financial sanctions.