Intersection of Anti-Corruption and Bribery with Sanctions and AML programs

Overview: Sanctions are an evolving tool us foreign policy used by governments and multi-national bodies to affect change in behavior and impose penalties for a variety of activities. Policy makers continue to explore new uses for and targets of sanctions prohibitions. On June 3, 2021, the Biden Administration announced that fighting corruption was a core U.S. national security interest and announced its intent to fight illicit finance. Later that month, the Financial Crimes Enforcement Network incorporated corruption as the first area of concern referenced in its Anti-Money Laundering and Countering the Financing of Terrorism National Priorities. Sanctions programs administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control may target corruption as part of a larger crisis (i.e., Venezuela) or may target corruption in its own right through the Global Magnitsky Sanctions Program. In the UK, the Office of Financial Sanctions Implementation maintains its own Global Anti-Corruption Sanctions program, which went into effect in 2021.

Just as the policy interests of various government regulators converge, design of an anti-financial crime compliance program should likewise emphasize interconnected risks related to corruption, sanctions, and money laundering. Teams dedicated to supporting topic-specific threats must partner with their colleagues across the second line to ensure appropriate issues are identified and acted upon. This session will outline developments with regard to Anti-Corruption initiatives by governments and provide key questions sanctions professionals should be asking of their own program and of their compliance colleagues.