The Compliance office(r) is also at war
Due to the escalation and length of the aggression, we have a new critical role in complying with the business risks sanctions, safeguarding human rights, restoring an open, respectful, and sustainable society, and also stopping dictatorship, supporting democracy and peace. The organisation’s role will significantly impact your customers, employees, and stakeholders:
- Strengthen the investigation processes to detect, evaluate, investigate, and close apparent or real cases of non-compliance. Regularly make the investigations’ efforts, numbers, and results visible to the organisation and stakeholders.
Identify and prevent transactions related to beneficial owners in Russia/Belarus, including politicians, oligarchs, elite’s related people, and state-owned enterprises starting from oil and defence companies. Identify alternative suppliers from Russia, create exit plans as part of the boycotting efforts, and address discontinuity risks. Activate exit actions for subsidiaries operating in Russia/Belarus to address potential counter-measure scenarios
Ensure sanction compliance with OFAC after the listing of VTB, Otkritie, Novikombank, and Sovcombank as Specially Designated Nationals and Sberbank, including subsidiaries https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20220224
Plan for the insolvency risks in transactions with Russian banks after the SWIFT ban and OFAC asset freeze. Reassess due diligence procedures and OFAC matches on third parties receiving new sanctions. https://home.treasury.gov/policy-issues/financial-sanctions/faqs/topic/1516 prevent the investment in and the financing of companies related to Russia and its government to avoid reputational and economic losses, including subsidiaries and beneficial owners,
Deal with the effect of export licenses cancellations and trade restrictions from Russian clients and suppliers, starting from direct technology exports. https://www.whitehouse.gov/briefing-room/statements-releases/2022/02/24/fact-sheet-joined-by-allies-and-partners-the-united-states-imposes-devastating-costs-on-russia/
Address reputational losses by cancelling sponsorships, JV, partnerships, and agreements with Russian/Belarus companies
Offer mental health, employment, and financial support to employees with families in Ukraine with a sensibility to employees in the Baltics, Poland, Romania, Slovakia, and Hungary. Raise awareness on the front-line staff to identify any business operation related to Russia
Assess measures against Venezuela, Belarus, Armenia, and other dictatorships supporting Russia. Channel donations and practical help for the people affected by the invasion.
Improve the efficiency of IT controls to prevent cyber-attacks from Russian/Belarus threat agents, starting from ransomware, phishing and distributed denial-of-services
If the corporate strategy contains words like ethics and integrity. In that case, it is the corporate duty to raise the voice and advocate stakeholders to take a clear and practical position to document the adopted corporate principles and values.
- Keep all information on investigations in compliance with the regulations of local jurisdictions for investigation processes and the transnational regulations.