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13) Does your organisation provide employees with regular sanctions training, including at onboarding?

August 19, 2021
Financial Risk
Sanctions Training

Answer yes if your organisation provides employees with regular sanctions training. Please describe the nature and frequency of the training within the notes. Please check our knowledgebase to review this control's applicability to your organisation.

It is illegal for any entities to conduct business with individuals or entities within countries that are currently under financial and trade sanctions. Furthermore, Firms which are subject to FCA regulations have a statutory and regulatory requirement to comply with the UK sanctions regime. This covers:

  • credit institutions;
  • financial institutions;
  • auditors, insolvency practitioners, external accountants and tax advisers;
  • independent legal professionals;
  • trust or company service providers;
  • estate agents;
  • high value dealers;
  • casinos.

For firms that exist outside of the above list it is still recommended that they complete a risk assessment to highlight where they are most exposed or at risk. Effective controls and processes should be implemented to mitigate this risk.

This control looks at whether your company provides sanctions training to your employees to ensure ongoing compliance with sanctions. This is typically combined within your wider AML controls as part of your KYC/KYB process.

Sanctions training is a great way for organisations that consider breaking international financial and trade sanctions a high risk (or regulated entities who are mandated through regulation to train their employees) to educate their employees on their specific sanctions responsibilities.

Training can be provided via e-learning or through face-to-face training sessions.

How to implement the control

There are a number of training providers that can provide sanctions training to your employees. The most common form of training is through the use of e-learning modules.

If implemented, training should be given at least annually.

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