AFB Virtual Seminar: The New UK Office of Trade Sanctions Implementation (OTSI) – Implications for Foreign Banks

AFB and Ashurst invite you to attend a virtual seminar exploring the implications for AFB members of the introduction on 10 October 2024 of the Office of Trade Sanctions Implementation (OTSI).

OTSI – the sister organisation of the Office of Financial Sanctions Implementation (OFSI) – will be responsible for administering UK trade sanctions laws and will have the power to impose civil monetary penalties for breaches of certain trade sanctions on a strict liability basis. Under the Trade, Aircraft and Shipping Sanctions (Civil Enforcement) Regulations 2024, which create the legislative framework for OTSI, banks and other FCA-authorised firms will also be required to report to OTSI if they suspect a breach of trade sanctions.   Please see the OTSI website here for further information.

Why attend?

UK sanctions typically contain prohibitions on the provision of financial services or funds, directly or indirectly, relating to sanctioned trade. These restrictions are relevant to all AFB members, but especially those that engage in trade finance activities or facilitate cross-border payment flows from the UK. 

Following the introduction of OTSI, AFB members are now subject to new reporting obligations and increased enforcement risks if they get trade sanctions compliance wrong. This also comes at a time of heightened focus by the FCA on the sanctions systems and controls of regulated firms.

This seminar will provide practical tips on the approach you may wish to take to ensure that you effectively update your policies and procedures, have appropriate reporting mechanisms in place, provide adequate compliance training and are able to investigate concerns related to the new obligations.  The seminar will also share cross-border lessons learnt from similar trends in the US and EU regarding trade sanctions enforcement.

Who should attend?

This session is aimed at those working in Legal, Compliance and Risk Management functions, in addition to Senior Managers with financial crime responsibilities.

There will be an opportunity to ask questions during and at the end of the session.

Speakers

Andris Ivanovs, Counsel, Corporate Crime and Investigations

Andris is a white-collar crime and international regulatory compliance lawyer who advises financial institutions, corporations, and senior executives on regulatory and internal investigations and financial crime compliance matters. He regularly advises clients on government-initiated and internal multi-jurisdictional investigations into allegations of bribery, corruption, money laundering, fraud, violations of sanctions or export controls, and other sensitive matters. Andris has experience in acting for clients facing investigations and proceedings brought by UK, U.S. and European enforcement or regulatory authorities.

In addition, Andris regularly counsels clients on proactive compliance and risk management under UK, EU, and U.S. anti-money laundering, anti-corruption and sanctions and export control laws, including in the context of cross-border transactions and business agreements.

Tom Stroud, Senior Associate, Corporate Crime and Investigations

Tom focuses his practice on white collar crime and contentious regulatory matters concerning sanctions, money laundering, corruption, fraud, tax evasion and market abuse. He advises both organisations and individuals on multi-jurisdictional internal, criminal and regulatory investigations and prosecutions undertaken by authorities such as the SFO, FCA, HMRC and the CPS. Tom regularly advises clients across a range of sectors on compliance with UK and EU financial and trade sanctions, including interactions with OFSI, ECJU, and EU and Member State authorities. Tom also advises clients on the development of best-practice financial crime systems and controls.

Please note, you will receive a confirmation of your booking via email within 24 hours. Should you not receive a confirmation, please contact AFB to double check if your booking was successful.

Logistics

Cost:        Included in AFB membership (no fee)

Location:  Virtual via Zoom, log in details will be sent one week prior to the event

Date:        Friday 15 November 2024

Time:        09:15 – 10:30