Sanctions

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:

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
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
Risk Assessment:

design and conduct a comprehensive risk assessment to assess your sanctions risk
Financial Crime Framework:

Assess and enhance sanctions-related policies, standards and procedures
Programme Transformation:

Designing and implementing a comprehensive sanctions programme
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
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.

Advisory & Transformation

Clients typically engage us when they have been subject to regulatory feedback, are expecting a visit from the regulator, or have concerns and want to take proactive action. Regardless of the situation, we can help.

S166 Skilled Person Services

Under the Financial Services and Markets Act 2000 (FSMA), the FCA’s Section 166 review is an independent review by a third party (a ‘skilled person’) about aspects of a regulated firm’s activities where the FCA has concerns or requires further analysis.

Fraud Practice

Global regulatory shifts are compelling financial organisations to prioritise fraud prevention more than ever, and rising fraud complexity highlights the critical role of operational teams as the first line of defence.

Digital Assets Practice

In slightly more than a decade, the digital assets industry has skyrocketed to a market cap of over 2 trillion USD, bringing innovations poised to revolutionise monetary systems, financial services and beyond.

Technology Advisory Services

Regulated firms face a constant battle against financial crime, and technology plays a crucial role in this fight. However, leveraging technology and keeping up with innovation comes with its own set of challenges.

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.

KYC Managed Service

The regulatory landscape continues to evolve placing increased regulatory pressure and demand on institutions to meet their KYC/CDD compliance obligations, often at significant cost.

RegTech Products

Our RegTech subscription products enable our clients to manage financial crime obligations, country and client risk more effectively while reducing internal risks, costs and resource demands.