1. Register Now | 888 224 2480 | AmericanConference.com/EconomicSanctions
a C5 Group Company
Business Information in a Global Context
Sponsored by
ACIAmerican Conference Institute
Business Information in a Global Context
Convening top financial institutions and leading
exporters, this unique forum addresses the most
pertinent sanctions issues:
Iran: Identifying allowed transactions and
leveraging potential business opportunities
associated with General Licenses H, I and J
Russia/Ukraine: How to make sectorial
sanctions operationally viable within your
compliance organization
Screening Best Practices: Special focus on
screening tools, how to mitigate false positives
and effectively allocate compliance resources
Beneficiary Ownership: How to apply the
50% rule and meet increasingly complex due
diligence requirements
Cuba Sanctions: How to validate sustainable
business
Status Update on New York State sanctions
regulatory and certification requirements
Register Now | 888 224 2480 | AmericanConference.com/EconomicSanctions
a C5 Group Company
Business Information in a Global Context
Train your global compliance team.
Group discounts available.
Reserve your seat early as this forum is expected to reach capacity.
7th Annual New York Forum on
Economic SanctionsAndaz Wall Street, New York, NY | December 6-7, 2016 EARN CLE/CPE
CREDITS
Interactive Working Groups, December 5, 2016:
Comprehensive Overview of U.S. Economic
Sanctions Regulatory Regimes and the Essential
Elements of an Effective Compliance Program
How to Assess the Effectiveness of Your
Sanctions Compliance Program: A Practical
Guide to Effectively Monitoring, Testing and
Auditing Your Controls
A B
Benchmark with:
Bank of the West
Blackrock
BNP Paribas
Boeing
Capital One
Crédit Suisse
Deutsche Bank
E*Trade Financial Corp
GE Capital
IBM
JPMorgan Chase & Co.
MasterCard
Noble Energy
Nokia
Pfizer
Société Générale
Standard Chartered Bank
UBS
Wells Fargo
Keynote Address
from:
Brad Smith
Chief Counsel
(Foreign Assets Control)
U.S. Department of the
Treasury
2. Join the Conversation @ACI_Finance #ACISanctions Financial Services
In its 7th
successful year, ACI’s New York Forum on Economic
Sanctions is widely regarded as the premier, flagship and most
comprehensive conference in the United States. Intensified economic
sanctions enforcement, higher compliance standards and the fast-
evolving regulatory landscape make sanctions compliance a top priority
for global organizations. With high profile investigations and multi-
million dollar penalties making headlines, it is no surprise that there is
continued interest in this complex and quickly-evolving space.
This forum convenes a diverse mix of financial institutions, exporters
and their advisers to provide practical and timely, country-specific
sanctions insights and address how to update sanctions compliance
and risk management programs.
Updated for 2017 to incorporate the most significant developments,
this program offers interactive analysis on:
• Iran Opportunities and General Licenses Nearing One Year
from Implementation Day
• Latest Additions to the Russia/Ukraine Sectorial Sanctions
• Challenging Case Scenarios in Screening, Due Diligence,
Financing and Payments
• Recent Enforcement Cases and Lessons Learned for your
Compliance Program
• How to Build Relationships with OFAC
This forum takes an advanced approach to complex sanctions topics.
If you are interested in a more basic-level primer prior to the main
conference, we recommend you attend our Pre-Conference Working
Groups to get up to speed on all aspects of an effective sanctions
compliance program.
Group pricing is available. Send your entire team and register early
as this forum is expected to fill to capacity.
Call 1-888-224-2180 or register online at:
www.AmericanConference.com/EconomicSanctions/
Accreditation will be sought in those jurisdictions
requestedbytheregistrantswhichhavecontinuing
education requirements. This course is identified
as nontransitional for the purposes of CLE accreditation.
ACI certifies that the activity has been approved for CLE credit by the New
York State Continuing Legal Education Board.
ACI certifies that this activity has been approved for CLE credit by the
State Bar of California.
You are required to bring your state bar number to complete the
appropriatestateformsduringtheconference.CLEcreditsareprocessed
in 4-8 weeks after a conference is held.
ACI has a dedicated team which processes requests for state approval.
Please note that event accreditation varies by state and ACI will make
every effort to process your request.
Questions about CLE credits for your state? Visit our online CLE Help
Center at www.americanconference.com/CLE
Continuing Legal Education Credits
EARN CLE
CREDITS
American Conference Institute (ACI) will apply for
Continuing Professional Education credits for all
conference attendees who request credit. There are no
pre-requisites and advance preparation is not required to
attend this conference.
Course objective: Timely updates to economic sanctions, internal risk
assessments and investigations, reporting requirements and transaction
due diligence. Prerequisite: None. Level of knowledge: Beginner/
Intermediate. Teaching Method: Group-Live. Advanced Preparation:
None. Delivery method: Group Live.
Please refer to the information in this brochure for outline, course
content and objectives. Final approval of a course for CPE credits belongs
with each states’ regulatory board.
ACI is registered with the National Association of State Boards of
Accountancy (NASBA) as a sponsor of continuing professional education
on the National Registry of CPE Sponsors. State boards of accountancy
have final authority on the acceptance of individual courses for CPE
credit. Complaints regarding registered sponsors may be addressed
to the National Registry of CPE Sponsors, 150 Fourth Avenue North,
Suite 700, Nashville, TN, 37219-2417 or by visiting the web site:
www.learningmarket.org
To request credit, check the appropriate box on the Registration form.
Continuing Professional Education Credits
PanAmerican
Seed Company
Pays $4,320,000
to Settle Potential
Civil Liability for
Alleged Violations
of the Iranian
Transactions
and Sanctions
Regulations
OFAC Website,
September 2016
Advanced Discussions on
Leading Sanctions Issues
Economic Sanctions in the Headlines
Vice Presidents, Directors,
Managers and Specialists of:
•• OFAC Compliance
•• Global Sanctions
•• Financial Crime
•• AML
•• Regulatory Compliance
•• International Trade Compliance
•• Internal Audit
•• Global Finance Customer
Identification
•• Transaction Monitoring
Corporate Counsel
specializing in:
•• Sanctions
•• International Trade
•• Export Compliance
Outside Counsel
specializing in:
•• Sanctions
•• OFAC
•• International Trade Law
•• Export Controls
•• Regulatory Compliance
•• Banking/Insurance Law
•• Financing Crime
•• AML
A Conference Designed for:
IranCallsonUSto
RemoveObstacles
toItsPurchaseof
PassengerPlanes
The Guardian, September 2016
U.S. to End
Economic Sanctions
Against Myanmar
Wall Street Journal, September 2016
EU Extends Economic
Sanctions on Russia by
Six Months
Wall Street Journal, July 2016
U.S.LiftsEconomic
Sanctionson
Côted’Ivoire
The National Law Review,
September 2016
3. Register Now | 888 224 2480 | AmericanConference.com/EconomicSanctions
a C5 Group Company
Business Information in a Global Context
Interactive Pre-Conference
Workshops | December 5, 2016
9:00 – 12:30 (Registration begins at 8:30)
Comprehensive Overview of U.S. Economic
Sanctions Regulatory Regimes and the Essential
Elements of an Effective Compliance Program
Tina Shaughnessy
Senior Counsel &
Program Manager –
International Trade
Compliance
General Electric
Company
(Washington, DC)
Geoffrey Goodale
Partner
FisherBroyles LLP
(Washington, DC)
This interactive and practical workshop is designed both for those
new to sanctions regulatory compliance as well as those in need of an
in-depth and comprehensive refresher prior to the more advanced
discussions of the main conference. Learn the nuts and bolts of how
OFAC’s comprehensive and limited sanctions programs operate,
including discussion on Myanmar, Cuba, Iran, North Korea, Russia,
Syria and Sudan. In addition:
• Understand how OFAC’s list-based and sectorial sanctions
programs include a range of subtle nuances that can expose U.S.
persons to civil and criminal liability
• Discover how statutory exemptions, general and specific licenses
allow for the processing of otherwise prohibited activity
• Review of OFAC’s reporting requirements and the Economic
Sanctions Enforcement Guidelines
• Learn how to leverage best practices in the development of a
global sanctions compliance program to protect you against
enforcement actions
• Delve in practical case studies applying U.S. sanctions regulations
in real-life situations
1:30 – 5:00 (Registration begins at 1:00)
How to Assess the Effectiveness of Your Sanctions
Compliance Program: A Practical Guide to
Effectively Monitoring, Testing and Auditing Your
Internal Controls
Barbara Linney
Member
Miller & Chevalier Chartered
(Washington, DC)
Constant evaluation of your sanctions compliance program is critical
to its success. This practical and hands-on workshop gathers expert
leaders to share best practices on how to approach monitoring, testing
and auditing processes on a global scale. The interactive session will
provide insights into fundamental evaluation techniques, common
risk areas and explore tailored strategies to address those risks. Take
advantage of this opportunity to benchmark your risk assessment
program against industry peers. Discussion topics include:
• Implementing a review and monitoring process for a global
sanctions compliance program
• Developing a risk-based approach to compliance program audits
• Focusing limited resources to maximize program effectiveness
• Comparing the pros and cons of internal audit, external audit,
and involving consultancies
• Timing and frequency of the review
• Understanding risk-based compliance: Adapting to OFAC
requirements and updating compliance policies in light of audit
results
Day 1 | December 6, 2016
8:45 Co-Chairs Opening Remarks
Molly Miller
Senior Director,
Economic Sanctions
and Trade Controls
Capital One
(New York, NY)
Adam Smith
Of Counsel
Gibson, Dunn &
Crutcher LLP
(Washington, DC)
9:00
Practical Dissection of Iran Sanctions in the US and
the EU: What Transactions are Actually Allowed and
How You Can Qualify Under General License H, I or J
Frederick Shaheen
Chief Counsel, Global
Trade
The Boeing Company
(Washington, DC)
David Peyman
Director, Global Lead,
Sanctions
Blackrock
(New York, NY)
Aleksi Pursiainen
Head of Trade
Compliance
Nokia
(Finland)
Kenneth Rivlin
Partner
Allen & Overy LLP
(New York, NY)
Nearing a year from Implementation Day, OFAC has released various
guidance and numerous general licenses for companies to leverage
business potential in Iran. This panel debunks hearsay, taking a
practical approach to what is actually allowed and provides timely
considerations in terms of business opportunities:
• Overview of current economic sanctions in place against Iran
• How have various industries been impacted by Iran
sanctions reform: banking, insurance, infrastructure, energy,
manufacturing
• Reputational Considerations/State Department encouraging
permissible business activities
• Identifying risks presented by multijurisdictional compliance
requirements for European and multinational companies
exploring business with Iran
• Understanding the scope and application of General Licenses H, I
and J for exporters and financial institutions
• Protecting your company against the risk of sanctions policy
“snap back”
• Iran domestic business and political response to JCPOA
10:00
Iran Due Diligence Scenarios:
What Would You Do If...
Alice Rojas
Head, Sanctions
Governance & OFAC
Reporting
Standard Chartered
Bank
(New York, NY)
Holly Whitmore
Lead Analyst,
Sanctions &
Anti-Corruption
GE Capital
(Norwalk, CT)
Khalil Maalouf
Counsel
Skadden, Arps, Slate
Meagher & Flom LLP
(Washington, DC)
Participate in a series of complex due diligence case studies (for both
financial and non-financial organizations) to analyze and resolve issues
that non-U.S. entities owned or controlled by U.S. persons confront
when doing business with Iran. Presenters and attendees will work
collaboratively in assessing the impact on the non-U.S. entity and U.S.
person if:
• the non-U.S. entity’s IT platform is housed on a U.S. server
• the non-U.S. entity would like to establish a foreign presence
in Iran
• the technology the non-U.S. entity sells is U.S. origin
4. Join the Conversation @ACI_Finance #ACISanctions Financial Services
• the U.S. parent’s banking agreements are with U.S. financial
institutions
• key corporate functions and group approval decisions on which
the non-U.S. entity relies are located and made in the U.S.
11:00 Networking Break
11:15
Making Sectorial Sanctions Operationally Viable:
Best Practices in Russia/Ukraine Sanctions Day-to-
Day Workflow and Other Sectorial Considerations
Ashley Coselli
Compliance Attorney
Noble Energy
(Houston, TX)
Brian Wilson
Executive Director,
Global Head of
Sanctions
UBS
(New York, NY)
• Overview of current economic sanctions in place against Russia/
Ukraine
• Best practices for integrating the unique sectorial sanctions
approach into screening, due diligence and compliance processes
• Unique challenges of applying ownership rules within the Russia/
Ukraine sanctions environment
• Preparing for the possibility of sectorial sanctions in other markets
and structural considerations for your compliance program
12:15
Identifying the Beneficial Owners of an Entity: How
to Effectively Apply the 50% Rule and Ownership
Nuances Across Sanctions Regimes
Kelly Gentenaar
Vice President for AML
E*TRADE
(Washington, DC)
Anders Rodenberg
Director, Financial
Institutions & Advisory,
North America
Bureau van Dijk
(New York, NY)
Jonathan Thomas
Co-Head Government
Sanctions Group
Goldman Sachs
(New York, NY)
Elizabeth Davy
Partner
Sullivan & Cromwell
LLP
(New York, NY)
• Understanding how ownership issues are flagged in compliance
programs
• Practical review of the 50% rule in the context of both sectorial and
non-sectorial sanctions
• How to make decisions and assess risks with incomplete and/or
imperfect information
• Establishing policy for assessing ownership where there is little
transparency
• Best practices in document compliance
1:00 Networking Luncheon
2:15
Cuba Sanctions in Practice: How to Validate
Sustainable Business Opportunities Within
Reformed Regulations
Howard Fields
Senior Vice President/Group Head – AML, Trade Sanctions
and Export Controls
Compliance Counsel
MasterCard
(New York, NY)
• Overview of current economic sanctions that remain in place
against Cuba
• Determining what is allowable under OFAC’s Cuba Assets Control
Regulations and the Export Administration Regulations
• Assessing risk appetite in Cuban business opportunities from U.S.
and non-U.S. companies, particularly in the technology, hospitality
and telecommunications industries
• Update on financial institutions ability to process Cuban
transactions
3:00
Where Companies Go Wrong in the Screening
Process: Key Pitfalls to Avoid, How to Mitigate
False Positives, and Optimize Limited Compliance
Resources
Mike Boriboon
Senior Vice President,
Head of Sanctions
Bank of the West
(Los Angeles, CA)
Victoria Haynes
Corporate Trade
Compliance Director
Illinois Tool Works
(Chicago, IL)
Lillian Norwood
Manager, Government
& Regulatory Affairs,
Export Regulation
Office
IBM(Washington, DC)
• Approaches to the sanctions watchlist in the screening process,
driving factors, which lists to screen, and the consolidation/
segregation of lists
• Screening model validation expectations of regulators; proprietary
vs. vendor-licensed tools
• Filter tuning testing and calibration
• Alert case management and relevant recordkeeping for audit trails
• Available tools for manual vs. automated screening processes
3:45 Networking Break
4:00
Status Update and Q&A on New York State
Sanctions: How New Regulations and Certification
Requirements Affect Compliance Initiatives amidst a
Coordinated State/Federal Enforcement Landscape
Christopher Conroy
Chief, Major Economic
Crimes Bureau
New York County
District Attorney’s
Office
(New York, NY)
Jason Cowley
Chief, Money
Laundering & Asset
Forfeiture Unit
U.S. Attorney’s Office
of the Southern
District of New York
(New York, NY)
Moderator:
Seetha Ramachandran
Partner
Schulte Roth & Zabel LLP(New York, NY)
• New York State Department of Financial Services new Part 504,
banking division transaction and filtering program requirements
and certifications
• Understand the interplay between federal and state agencies,
particularly in New York, in terms of sanctions compliance
enforcement
• Interplay between state and federal sanctions, especially in terms
of the JCPOA
• Other states’ sanctions programs in which to be aware
5:00
Compliance Think Tank: Ensuring Your Compliance
Program and Risk Assessment Practices Meet OFAC
Accountability Requirements
Lorraine Lawlor
Senior Vice President,
Global Sanctions
Governance Director
Wells Fargo
(McLean, VA)
Brenton Petersen
Head of Sanctions
Risk Oversight
BNP Paribas
(New York, NY)
Amy Worlton
Partner
Wiley Rein LLP
(Washington, DC)
• Applying best practices in compliance structure, training, and
assessments
• How to ensure quality and consistency in your screening and due
diligence programs
• Approaches to assessing and managing sanctions risk across
multiple jurisdictions, including conflicts of law
• Identifying and adhering to all the reporting requirements of OFAC,
the SEC and the Fed
5. Register Now | 888 224 2480 | AmericanConference.com/EconomicSanctions
a C5 Group Company
Business Information in a Global Context
6:00 Conference Adjourns to Day Two
Day 2 | December 7, 2016
8:30 Co-Chairs Opening Remarks
8:45
Sanctions Violations in the News: Applying Lessons
Learned from Recent Cases and Coordinated
Government Investigations to Your Compliance and
Risk Management Initiatives
David Mortlock
Partner
Willkie Farr &
Gallagher LLP
(Washington, DC)
Anahita Thoms
Partner
Freshfields
(New York, NY)
• What key economic sanction cases of the past 12 months reveal
on how enforcement priorities are evolving
• Latest trends in sanctions enforcement against individuals post-
Yates memo
• What kinds of mitigating factors can limit your exposure to fines
and criminal liability?
• Enforcement of U.S.-based companies and those headquartered
outside the U.S.
• What is expected from your company if your industry is under
investigation
• How compliance efforts are rewarded
9:30
The Anatomy of a Government Investigation:
Former Prosecutors and Agents Reveal Red Flags,
Key Investigative Techniques, and the Extent of
Government Coordination
Joshua Holzer
Chief Counsel for
Global Trade
Pfizer
(New York, NY)
Molly Miller
Senior Director,
Economic Sanctions
and Trade Controls
Capital One
(New York, NY)
Lisa Prager
Partner
Holland & Knight LLP
(New York, NY)
Thomas Feddo
Partner
Alston & Bird LLP
(Washington, DC)
• Typical “red flag” indicators alerting the government to a potential
sanctions violation
• Factors to consider when managing a multi-agency and/or multi-
jurisdictional investigation
• How enhanced coordination between U.S. government agencies
affects investigative processes
• Satisfying government requests for employee interviews: When/
when not to dismiss an employee suspected of wrongdoing vs.
keeping them employed
• How to manage the submission of documents to multiple
governments: Responding to government document requests
amid data privacy and state secret constraints
10:30 Networking Break
10:45
What to Do When You Suspect a Violation? Tips for
Internal Investigations and Determining the Value
of a Voluntary Self-Disclosure
John Reynolds
Partner
Davis Polk &
Wardwell LLP
(Washington, DC)
Betty Santangelo
Partner
Schulte Roth & Zabel
LLP
(New York, NY)
Scott Horton
Associate General Counsel, Financial Crimes Group
Global Legal, Compliance and Regulatory
AIG (New York, NY)
• Key analyses to determine the root cause of the issue (i.e.
technical vs. human error)
• Identifying who should conduct the investigation, and
coordinating their roles: In-house compliance and legal groups vs.
outside counsel and forensic accountants
• Special considerations for internal investigations involving a
foreign subsidiary or affiliate
o Reconciling investigative objectives with foreign privacy laws
and blocking statutes
o Collecting and preserving documents in and outside of the US
• How to document your findings
• Do’s and don’ts for drafting a voluntary disclosure
• How voluntary disclosures impact penalty calculations
11:45
OFAC Alumni Share Best Practices as to How to
Effectively Work with OFAC
Brandon Reddington
Vice President, Global
Sanctions Compliance
Credit Suisse
Formerly with OFAC
2009-2014
(New York, NY)
Saam Youssefi-Rad
Vice President, Head
of OFAC and Sanctions
Compliance, Americas
Deutsche Bank
Formerly with OFAC
2006-2009, US DOT
2009-2012
(New York, NY)
Adam Smith
Of Counsel
Gibson Dunn &
Crutcher LLP
Formerly with OFAC
2010-2015
(Washington, DC)
• The importance of building a good relationship with OFAC
• How to best obtain necessary licenses and glean important
guidance
• Anticipated timeframe for OFAC responses
• Question and answer opportunity with former OFAC leaders
12:45 Networking Luncheon
2:00 Keynote Address
Brad Smith
Chief Counsel (Foreign Assets Control)
U.S. Department of the Treasury (Washington, DC)
2:30
Mitigating Facilitation Risks: The Top 5 Red Flags
that Could Indicate a Facilitation Issue
Allie Cheatham
Executive Director,
Compliance Director,
Global Sanctions
Compliance, Advisory
& Investigations
JPMorgan Chase & Co.
(New York, NY)
Sheena Nayak
Vice President,
Sanctions Compliance
Societé Générale
Corporate and
Investment Banking
(New York, NY)
Les Carnegie
Partner
Latham & Watkins
LLP
(Washington, DC)
• Review of available guidance in terms of what qualifies as
“facilitation”
• How to uncover whether a client happens to be controlled by a
designated entity
• What to do when there is a lack of reliable public data available
when dealing with state-affiliated clients
6. Join the Conversation @ACI_Finance #ACISanctions Financial Services
• Understanding facilitation risks in the context of the Iran
Sanctions and the JCPOA
3:30 Networking Break
3:45
A New Era in Myanmar: What Does the Lifting of
Sanctions Mean for Business?
Eric McClafferty
Partner
Kelley Drye & Warren
LLP
(Washington DC)
Erin Crockett
Global Director Trade
Compliance & ITPSO
Colfax Corporation
(Annapolis Junction, MD)
• Communicating the risk/reward of these new business
opportunities with management
• Process for reinstating business operations with a long-
sanctioned country
• Potential for sanctions “snapback” given the sustained military
influence on the democratic administration
• Other lingering regulatory considerations
4:15
Applying the Appropriate Level of Due Diligence
Across Sanctions Regimes: Practical Scenarios in
Screening, Sourcing, Financing, and Payments
Brian Wilson
Executive Director,
Global Head of
Sanctions
UBS
(New York, NY)
Daniel Gerkin
Counsel
Vinson & Elkins
(Washington, DC)
Aleksi Pursiainen
Head of Trade
Compliance
Nokia
(Finland)
This interactive closer engages the audience in several complex
sanctions scenarios. After a review of each scenario and all the
challenges involved, expert speakers will take the audience through
a step-by-step review of effective due diligence strategies to address
each situation. The audience will be provided with the opportunity to
vote on what is the best course of action. Don’t miss the chance to test
your business acumen and benchmark with your peers during this
insightful and interactive new panel.
• Compliance throughout your Supply Chain: Despite significant
screening practices, the third party you are working with ends up
touching an SDN.
• Teaming Agreement: You are working with a Canadian partner
to complete a transaction. However, your partner has a U.S.
embargoed person involved in that transaction that isn’t subject
to Canadian sanctions.
• Third-Country Symposium: A foreign partner’s event is being
hosted in a third-country, and there are people from sanctioned
countries in attendance. Would this be considered facilitation if it
is a private event?
• Payments and Financing: You are a U.S.-based, global financial
institution supporting payment for a transaction initiated by a
Mexican company exporting to Cuba. The end-user passed all of
your screening lists. Is this transaction allowable?
5:15 Conference Concludes
2015 New York
Forum Reviews
“Excellent conference, very useful!”
–PayPal
“This was a very informative
conference. Great panelists.”
–BNP Paribas
“Speakers and presentations were
extremely helpful and provided great
information.”
–Fifth Third Bank
Join a Senior-Level
Audience from:
Finance
Accounting
Manufacturers
Insurance
Aerospace
Technology
& Software
Energy
Law Firms
Life Sciences
Retailers
Transportation
Automotive
Telecom
8. B00-840-840L17.WEB
REGISTRATION CODE
Attention Mailroom
If undeliverable to addressee, please forward to:
Vice Presidents, Directors and Counsel of
OFAC Compliance, Economic Sanctions, AML,
Financial Crime, Regulatory Compliance,
Export Controls, International Trade
Compliance, Government Relations
Incorrect Mailing Information
If you would like us to change any of your details,
please email Data@AmericanConference.com
or fax the label on this brochure to 1-877-927-1563.
American Conference Institute
45 West 25th
Street, 11th
Floor
New York, NY 10010
Need an Economic Sanctions Primer Prior to the Main Conference?
Our pre-conference workshops on December 5th provide a comprehensive
overview of U.S. sanctions regulatory regimes and how to assess the
effectiveness of your sanctions compliance program.
ACIAmerican Conference Institute
Business Information in a Global Context
7th Annual New York Forum on
Economic SanctionsAndaz Wall Street, New York, NY | December 6-7, 2016
EARN CLE/CPE
CREDITS
7th Annual New York Forum on
Economic SanctionsAndaz Wall Street, New York, NY | December 6-7, 2016 EARN CLE/CPE
CREDITS
