Sanctions Flashcards
Sanctions
instrument of foreign policy used by countries & international organizations to impose restrictions against countries, goods, individuals to achieve political or security objective
who can impose sanctions?
Countries
Supra-national & regional organizations (UN, EU)
What are the types of sanctions?
Embargo/comprehensive
Sector based sanctions
Financial sanctions
Arms embargo
Secondary sanctions
Embargo/comprehensive
prohibition to trade w/in geographical region
Sector based sanctions
specific targets (commodities, travel restrictions)
Financial sanctions
asset freeze, credit terms restriction
Arms embargo
weaponry, dual/use items
Secondary sanctions
pressure on 3rd parties to stop their activities with sanctioned countries
What levels of regulations is MSC subject to?
Swiss, EU, USA, and local
Name 3 countries subject to MSC sanctions
Cuba, Syria, North Korea
How can authorities find out about sanctions violations?
Self disclosure, competitor tips, whistle blowers, customs checks
What are the consequences of violating sanctions?
Fines, criminal prosecution, reputational harm, investigation costs, designation by organizations
What are the elements of an effective compliance program?
Established policies & controls
Oversight
Due diligence
Education & communication
Monitor & audit program
Respond to incidents
Promotion & enforcement
BEF
Doc with specific details that allows compliance to evaluate shipment involving sanctioned entity
IMPAQ
Sanctions software that scans parties