Resourcing And Training Support For Client To Ensure They Were Adhering To All Applicable Sanctions’ Regimes And Effectively Managing Their Sanctions Exposures
The Client’s Needs
The client is a large multi-national insurer with company and Lloyd’s syndicate capacity. They had exposures in multiple territories that were subject to sanctions and required support with managing and responding to these.
ICSR were engaged to:
- Provide advice to the business on how to manage their sanctions exposure,
- Liaise with regulators in the UK and Internationally, (Office of Financial Sanctions Implementation (OFSI), Office of Foreign Assets Control (OFAC), and Lloyds),
- Liaise with internal & external legal representatives on complex sanctions matters,
- Liaise with Xchanging for high-risk sanctions touchpoints on the syndicate platform,
- Advise and assist with completion of the annual financial crime risk assessment,
- Advise and assist on the effective use and set-up of the current financial crime screening tool,
- Advise and assist offshore business units with file reviews,
- Advise and assist the Finance team manage payment requests with a sanction’s touchpoint,
- Advise and assist the Claims team with sanctions exposure management,
- Assist with the training of the client’s new full-time sanctions resource.
ICSR’s Solution
ICSR worked with the business to manage their sanctions exposure across multiple business teams impacted by sanctions controls in different jurisdictions. We provided a resource that could liaise directly with regulators and external legal counsel to ensure the client did not breach their sanctions obligations in a variety of complex scenarios. ICSR helped identify gaps in procedures to ensure the escalation process was enhanced, providing a more streamlined approach whilst improving the MI capability on sanctions exposure for the Compliance function.
Resources Deployed
ICSR deployed a Senior Consultant who worked full time with the client for 9 months.
Client Outcome
The client successfully met their Legal and Regulatory requirements for applicable sanctions. A full-time resource is now in place to managing ongoing exposures.
