Financial sanctions are imposed by governments and multi-national organisations (the EU, UN, etc.) to further foreign policy objectives and prevent or disrupt criminal activities. Sanctions restrict the individuals, entities and/or countries that are subject to those sanctions from accessing financial resources and markets. To date, the focus has been on financial institutions, but all individuals and companies are now required to comply with sanctions regulations in the jurisdictions that they operate in.
Achieving compliance is a complex process. Regulations frequently vary across separate jurisdictions and their requirements change constantly. Only limited guidance is available from the regulators and authorities themselves.
Deloitte has unparalleled experience in this area, having designed, reviewed, enhanced, implemented and monitored numerous financial sanctions detection and compliance programs for clients around the world. The team has established strong relationships with key relevant regulatory authorities and advised financial and non-financial institutions on a wide range of sanctions compliance matters.
Our work has included assessing sanctions risk at the enterprise and business unit level, drafting and enhancing policies and procedures, creating and delivering training modules, compliance assessments, retrospective "look back" investigations following regulatory orders, internal controls assessments, selection and implementation of technology solutions, internal investigations and the creation of enterprise-wide private sector Financial Intelligence Units (FIUs).