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Master Thesis International Sanctions Compliance As an Essential Element Master Thesis International sanctions compliance as an essential element of Know your customer procedure for global businesses Tilburg University Law School, Department of Business Law LLM Program: International Business Law Student: Diana Vasileva ANR 476237 Supervisor: Dr. J. Li, Assistant Professor 12 June 2017 1 CONTENTS List of abbreviations used ............................................................................................................ 3 Introduction ................................................................................................................................... 4 CHAPTER 1 .................................................................................................................................. 6 Legal and economic nature of sanctions ..................................................................................... 6 CHAPTER 2 ................................................................................................................................ 17 Overview of the US and the EU sanctions regimes .................................................................. 17 CHAPTER 3 ................................................................................................................................ 38 Consequences of violating sanctions regimes and compliance-related problems that businesses face: ............................................................................................................................ 38 OFAC case study and a survey for legal professionals ............................................................ 38 CHAPTER 4 ................................................................................................................................ 50 Developing an effective sanctions compliance program for a global organization ............... 50 Conclusion ................................................................................................................................... 53 Annex 1 ........................................................................................................................................ 56 OFAC cases under analysis ........................................................................................................ 56 Annex 2 ........................................................................................................................................ 69 Survey for sanctions compliance professionals ........................................................................ 69 List of references ......................................................................................................................... 84 2 List of abbreviations used BIS- Bureau of Industry and Security DDTC -Directorate of Defense Trade Controls EAR- Export Administration Regulations ITAR- International Traffic in Arms Regulations JCPOA - Joint Comprehensive Plan of Action, concluded on 14 July 2015 KYC -Know your customer OFAC – Office of Foreign Assets Control SDNs list - Specially Designated Nationals and Blocked Persons List UN – United Nations 3 Introduction The issue of international sanctions compliance has recently become one of the most important challenges for large corporations, operating worldwide. It is obvious that in the epoch of globalization modern business environment is to a large extent dependent on economic and political processes that can be observed all over the world, therefore, creating additional risks for companies, managing units in various jurisdictions. From the historical perspective, economic sanctions, asset-freezing measures and product embargoes are not a new instrument, applied by regulators. However, today’s main concern, associated with them, is a fast increase in the scope and area of their application, and, therefore, a requirement for businesses to take additional control measures to ensure the corresponding compliance. The object of this academic paper is economic sanctions regimes and other measures of the same legal nature and purpose, taken by regulators worldwide. The aim of the present research is to prove that international sanctions compliance shall be considered an essential element of a corporate Know your customer procedure and to outline possible solutions for companies to hedge their respective risks. In order to achieve the above-mentioned aim of the research, a number of tasks shall be fulfilled: 1. analysis of legal nature and classification of economic sanctions; 2. overview of the EU and the US sanctions regimes, having the most serious impact on international groups of companies and regulatory bodies, responsible for their administration and enforcement; 3. the effect of existing sanctions regimes on global businesses to be studied by means of analyzing cases of the Office of Foreign Assets Control (OFAC) of the U.S. Treasury Department in the time span 2012-2017. The study is to identify the following: 1) industries under the highest risk of facing penalties for sanctions violation; 2) jurisdictions where the bigger share of violations occurs; 3) the amounts of penalties, imposed on companies; 4) aggravating and mitigating factors recognized by the regulator; 5) general tendencies in the regulators’ position regarding sanctions regime violations that can be observed in cases within the time span in question; 6) list of risk –hedging sanctions compliance measures for companies to be 4 developed. In addition to the case study, a survey for legal professionals, dealing with international sanctions compliance, is to be conducted and its results to be analyzed to highlight the difficulties that companies face when trying to fulfill the existing legislation requirements. The purpose of the survey is to prove that many companies understand the importance of sanctions compliance but the existing regulatory rules are not clear enough for them and the process of sanctions checks is extremely time-consuming and expensive. Finally, on the basis of the above-mentioned, major characteristics of an effective internal sanctions compliance program for global businesses are to be outlined and possible solutions to the existing compliance challenges to be proposed. 5 CHAPTER 1 Legal and economic nature of sanctions Chapter 1 is concerned with the nature of sanctions from legal and economic perspectives, their effect on business and their place in corporate due diligence processes. The goals to be achieved in the present chapter are: • to specify the main characteristics of a Know your customer procedure with regards to activity of international businesses; • to identify the basic elements that the concept of economic sanctions includes; • to outline the main functions of sanctions as a powerful economic instrument of influence on the world’s political arena; • to provide a general overview of the two major sanctions regimes – the US and the EU, applicable to most of companies, operating worldwide. 1.1.Know your customer procedure The concept of Know your customer procedure (hereinafter referred to as “KYC”) is widely used today in relation to corporations in various industries, operating internationally. The term reflects the due diligence process of a business verifying the identity of its clients in order to comply with the applicable regulatory requirements and hedge its respective operational risks. In order to understand the nature of KYC, firstly it shall be noted that in the narrow sense in relation to many companies carrying out their activity worldwide, KYC can be regarded as a financial regulatory requirement established by the US Bank Secrecy Act 1 and the USA PATRIOT Act 2 (Section 312 in particular), aimed at banks and non-banking financial organizations with the purpose of preventing money laundering and terrorist financing activities. 1 Major requirements of Bank Secrecy Act of 1970 can be found at the official page of the US internal Revenue Service at https://www.irs.gov/businesses/small-businesses-self-employed/bank-secrecy-act, accessed on 04.06.2017. 2 Official text of the USA Patriot Act (PUBLIC LAW 107–56—OCT. 26, 2001) is available at https://www.gpo.gov/fdsys/pkg/BILLS-107hr3162enr/pdf/BILLS-107hr3162enr.pdf, accessed on 04.06.2017. 6 However, recently the term KYC has become widely spread among compliance professionals in other industries as well, as today proper due diligence on third parties today is the burden not only of financial organizations but also of companies operating in other economic sectors; therefore, KYC procedure importance for them shall not be underestimated. Secondly, it is essential to state that nowadays global businesses have come to a deep understanding of the importance of well-structured and effective internal due diligence processes, as lack of these can result in various destructive consequences, including huge financial and reputational losses for the companies themselves, as well as criminal sanctions for their executives. The fact is supported by experts in the field of compliance and risk – management. Thus, according to Deloitte analysts, “conducting due diligence on international business partners has become a leading practice for companies operating in global jurisdictions. While the due diligence effort may lengthen the start-up time for a new business partner relationship, failing to do so can have considerable negative financial and operational repercussions for companies seeking to conduct business internationally” 3 . This point of view is shared by PricewaterhouseCoopers consultants in their
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