So, what does that mean for your organisation and how can you prepare yourself for the Post-Brexit world of sanctions? Here’s some things to know:
1. KNOW YOUR CUSTOMER BEYOND JUST A NAME
The government will gain the power to designate persons not only by name but also by a description in situations of asset freeze where it is difficult to identify by name alone, which could expand the reporting requirements. This change will increase the burden of screening within your organisation and create uncertainty for those tasked with identifying individuals, adding strain to the due diligence process. Therefore, it is necessary to update screening content subscriptions for any new DPL lists and ensure UK lists are updated daily.
2. BE COGNIZANT OF EU & UK SANCTION REGIME OVERLAPS & INCREASED REPORTING
Although similarities will exist for EU & UK sanctions and how they are applied, it will be pertinent to make sure you remain compliant amongst both regimes in case of any slight variations. The EU imposes reporting requirements on all natural and legal persons, but the UK reporting requirements currently only apply to some professionals and businesses. Under the Act, the UK will extend the reporting requirements to natural and legal persons. While this impact may not raise alarms for companies who already comply with EU requirements, some UK Businesses may face additional compliance burdens.
3. UK COULD TOUGHEN ITS STANCE ON HUMAN RIGHTS VIOLATIONS
The Magnitsky Powers allows the UK to impose sanctions to punish or deter violations of human rights and promote compliance with international human rights. However, it is not certain what the scope looks like for how the UK considers “respect for human rights.” This will result in the need for companies to carry out more stringent human rights’ due diligence for their value chain which will result in more checks, time planning and costs needed.
