A representative of UBCG participated in the workshop Mitigation of risks from complex sanctions in Montenegro. Sanctions and their application in Montenegro. Executive Order 14114 and what sanctions risks Montenegrin industry should take into account. Investigation of conflicts with local/regional regulations. Avoiding sanctions through ownership and control.
International sanctions regimes:
Understanding the framework, differences between OFAC and the EU, and the risks of non-compliance. Purpose and objectives of sanctions and trade controls, their importance for the financial sector. The legal and regulatory framework governing sanctions and trade controls: the regulatory environment in the EU, US, UK and other relevant jurisdictions.
Non-compliance risks, including enforcement trends and case studies. US Sanctions: OFAC Framework for Compliance Obligations.
Sanctions Circumvention: Evolving Transshipment Patterns. Typologies of Sanctions Evasion (Fachronistic and Fake Companies; Complex Ownership Structures, Use of Allies or Intermediaries, Mislabeling and Transshipments, Use of Non-Standard Payments, False Documentation and Exploitation of Jurisdictional Gaps, Deceptive Techniques Including Changing the Physical Identification of Vessels, False Flags. Exploiting the Global Supply Chain: Transshipments and Diversions of High-Tech Goods, Microelectronics and Related Components. Significance of the Joint High-Level List.
The workshop was organized and implemented by the Voluntary Financial Services Corps (FSVC), with the support of the US Department of State’s Office for Cooperative Threat Reduction (ISN/CTR), which is implementing a technical assistance program for the mitigation of complex sanctions risks. in accordance with the requirements of the sanctions which the awareness of typologies of avoidance is also changing, and public-private cooperation in connection with sanctions has strengthened.
