In “Navigating an Increasingly Complex Sanctions Landscape, Part 2: Compliance Programs and Remediation” (15 July 2020, FCPA Compliance Report), Adam Frey highlights how compliance professionals can navigate an increasingly complex sanctions landscape, providing some best practices for sanctions compliance programs. Additionally, he discusses what happens if there is a compliance failure by means of a sanctions breach.
According to Adam, “In terms of responsibility, at the end of the day it is up to every person in the organization to be aware of and own the sanctions risk of their business activity or their job function. The goal is really for the first line of defense to internalize the importance and the need for sanctions compliance and the sanctions risk in the same way they do for credit risk and other types of operational risks that they own. It is tone from the top or rather tone from management that is really critical in this regard.”
For additional information, tune into K2 Integrity’s sanctions podcast series with Tom Fox here.
