Sanctions Compliance Programs and Solutions

Goals

To find data on sanctions compliance programs and RegTech solutions in order to better understand how corporations can stay compliant and the technology tools/innovations that are useful for that purpose.

Early Findings

  • The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) published a paper in 2019 that contains a framework of compliance commitments. The document details OFAC’s views on the best practices that should guide coporations to ensure compliance with sanctions laws and regulations in the US.
  • Havard Law published an analysis of sanction compliance in the US, focusing on requirements detailed in OFAC's publication.
  • The Program on Corporate Compliance and Enforcement at New York University School of Law published a detailed paper titled "Economic Sanctions and Anti-Money Laundering Developments: 2018 Year in Review" that provides an in-depth discussion of "economic sanctions and anti-money laundering (“AML”) developments and trends in 2018 and outlook for the future."
  • Bloomberg published a paper on sanction compliance for enterprises working in various countries and how they can better comply with regulations globally.
  • A paper published by David Mortlock et. al. published a paper arguing that the "increased use of partial restrictions on sanctions targets creates more nuanced restrictions on companies and requires the development of more sophisticated compliance programs."
  • We also discovered a publication on how to implement and effective sanctions and export compliance program in a corporation.
  • According to an article by Hera Smith, a global sanction compliance officer with AFEX, the use of sanctions screening technology capable of adapting to changes has benefits for businesses but it can also pose some risks.
  • Based on Deloitte's data, there are at least 309 RegTech tools currently. About 123 are compliance solutions, 77 are identity management and control solutions, 45 are risk management solutions, 37 are regulatory reporting solutions, and 27 are transaction monitoring solutions.

Proposed next steps:

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