Sanctions
Sanctions have become invaluable tools in the foreign policy arsenal of states, and their use is likely to continue increasing in the future. They also will continue to underpin international strategies to combat terrorism and weapon proliferation.
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The risk of failing to comply with sanction designations
The speed at which governments and international organisations publish new sanction designations has increased exponentially in recent years, and it is set to continue to do so.
If a firm breaches sanctions, the consequences can be severe, including:
- Severe fines;
- Asset freezes;
- Criminal prosecution;
- Becoming the target of sanction designations; and
- Potential exclusion from the global financial system.
Moreover, firms can also incur harsh reputational damage. Financial institutions spend billions on marketing and communication strategies to influence how they are perceived by customers, shareholders, competitors and key decision-makers. Yet, the reputational damage from breaching sanction should not be underestimated.
How Plenitude can help
Regulators expect firms to have effective, up-to-date sanctions controls or a programme proportionate to the nature, size and risk of its business.
Our team of experts can help you navigate and meet your sanction obligations effectively and efficiently taking a ‘risk-based’ approach. Our services include:
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Independent Assessment:
executing a proportionate assessment of your sanctions controls or programme to manage compliance in readiness for regulatory reviews or to take proactive action
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Regulatory Reviews:
Supporting firms through S166 Reviews (firm-side) or conducting S166 Reviews on behalf of the FCC on the basis Plenitude is appointed to the Skilled Person Panel for Lot E: Financial Crime. Guiding firms through the remediation process linked to enforcement action or regulatory review
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Risk Assessment:
design and conduct a comprehensive risk assessment to assess your sanctions risk
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Financial Crime Framework:
Assess and enhance sanctions-related policies, standards and procedures
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Programme Transformation:
Designing and implementing a comprehensive sanctions programme
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Test and calibrate key sanction controls to your risk profile, such as:
- Name and payment screening,
- Supply chain due diligence; and
- Monitoring of trade finance
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As part of our Tech and Data Services:
- Health Check / Effectiveness Testing: End-to-end validation of screening platforms with regard to identifying gaps in risk coverage and options for improving efficiency and effectiveness
- Customer and Transaction Screening optimisation: Scenario assessments (condition and threshold), scenario testing, threshold tuning, scenario generation and effectiveness testing
- Watchlist optimisation: End-to-end review and optimisation of processes related to watchlist flows across the FCC landscape to ensure more effective and efficient detection rates for screening and monitoring
Our Services
Our capabilities address the entire spectrum of financial crime risks and, as a full-service provider, we can meet all of our clients’ needs in order to deliver a truly integrated consulting service. We can assist with a wide range of needs, including independent assessments, policy and standards enhancement, risk assessments, specialist tech and data support, and remediation and transformation program design and execution. No matter what the requirement, we are here to help.
Discover more about our services and see why our integrity, passion and delivery excellence have been praised by so many clients.
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Data Analytics Services
Data quality, siloed systems, and the ever-evolving tactics of criminals make effective data analysis a constant battle. Firms need to break down these silos to get a holistic view of customer activity and identify hidden patterns that might indicate a financial crime threat.
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Our specialists
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Daniel Keay
Senior Executive
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Jesal Punjani
Senior Executive
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Chief of Staff
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Munir Merchant
Head of Tech Advisory
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Manuel Fajardo
Head of Digital Assets
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Tom McKay
Head of Data Analytics
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Edward So
Head of Transaction Monitoring
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Alejandro Escolar
Head of Screening
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Alex Brennan
Senior Manager
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Manager
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Our best-in-class team are committed to building a secure financial system, safeguarding society, and empowering our clients to meet their regulatory obligations.
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