Following Russia’s invasion of Ukraine in February 2022, the US, UK and EU have imposed an unprecedented level of financial sanctions against Russia. The new sanctions block dealings with many Russian banks and restrict many types of business interactions.  Now, more than ever, it is important for businesses to keep track of sanctions and ensure their sanctions policy is up to date.

VinciWorks has created a free sanctions policy template that can easily be edited to suit your organisation, industry and staff, as well as remain relevant with all the current sanctions in place.

You can download the sanctions policy template for free by clicking on the button below.

Download sanctions policy template

What is sanctions compliance?

Sanctions compliance involves complying with restrictions that have been applied to sanctioned regimes. Sanctioned regimes generally include countries considered national security threats, such as Russia, North Korea, Iran and China, as well as countries with sub-par human rights records or significant corruption. The exact requirements for sanctions compliance will vary from country to country, depending on the level of sanctions being applied.

Businesses must understand what sanctions they are required to screen for and be able to prove that they are acting in compliance. Failure to do so can lead to significant fines. Sanctions lists can be searched easily online.

Companies that have operations, clients, suppliers or otherwise do business with a nexus to sanctioned countries must screen clients against their country’s sanctions list. This involves checking a database for the names of individuals, groups or companies. Entities on these lists may be sanctioned due to their geographic location or their partnerships and alliances.

New customers must be screened for sanctions as part of the onboarding process. Existing customers and third parties should also be screened on a regular basis in order to comply with the changing landscape.

Who needs to comply with sanctions regulations?

All businesses must comply with international sanctions. The first step to sanctions compliance is to understand where your business is exposed to sanctions. This will depend on where your business is based and the industry in which it operates. There may be different rules depending on your product, your customers, and how they use your merchandise after they buy it.

What should a Sanctions Policy include?

Defining sanctions

Start by explaining what sanctions are. Sanctions are restrictions on activity with targeted countries, governments, entities, individuals and industries (‘targets’) that are imposed by bodies such as the United Nations (UN), the European Union (EU), individual countries or groups of countries.

Comparing sanctions to anti-money laundering

The sanctions regime is not the same as the Anti-Money Laundering regime and it is important for staff to know the difference. This section should explain this difference.

Who is responsible for the sanctions policy?

Give details of who the Nominated Officer is. This person is responsible for ensuring the policy is adhered to by all staff.

Risk assessment

Has your organisation carried out a sanctions risk assessment? The risk assessment procedures, and any results to note should be included here.

Company procedures

Your organisation should have clear sanctions procedures in place and include those procedures in the policy.

What training is provided on sanctions?

Your policy should outline the training your staff will be given on sanctions.

Consequences of non-compliance

Are your staff aware of the importance of adhering to the sanctions policy. This should be highlighted by pointing out the implications of non-compliance, which could result in disciplinary action or even dismissal.

Download a free sanctions policy template

VinciWorks’ sanctions policy template can easily be edited to include your organisation’s name and the contact details of the Nominated Officer. You can download the template here.