Association of Certified Sanctions Specialists Tools Kit
Every Thing You Need to Create Your Own Sanctions Program
Documentation
Process
Step 1: Understanding the Basics
What the Video “What Are Sanctions and How Does it Affect my Business
Step 2: Which Sanctions Apply to Me?
Fill in the online form
Step 3: Designate a Sanctions Officer
- Read the Job Description
- Fill in Board Resolution Template to Designate the Sanctions Officer
- Save the PDF of the designation
Step 4: Getting Started with a Culture of Compliance and Basic Compliance Structure
Fill out the form “Sanctions Risk Assessment”
- Watch the video “Structure of Compliance”
- Watch the video “Role of Senior Management”
Step 5: Assessing the Sanctions Risk of Your Business
Fill out the form “Sanctions Risk Assessment”
- Answer questions to understand the risks your business faces
- Assess the extent to which existing internal controls mitigate the risks identified
- The outcome is your business’ “Sanctions Risk Assessment”: The findings are a recorded in a written “Risk Assessment” report outlining which sanctions risks are most pressingly facing your business and which existing internal controls are in place to mitigate these risks. It will describe gaps and include action items to be implemented in order to mitigate the weaknesses. This way you can easily prioritize the action items when using this this toolkit.
Step 6: Creating a Sanctions Compliance Policy
- Fill out the template
- Save the PDF document
Step 7: Creating Internal Controls to Ensure Compliance with Sanctions
- Fill out the template “Internal Controls”
- Save the PDF document
Step 8: Due Diligence and Vetting Third Parties
- Fill out the template “due diligence”
- Save the PDF due diligence questionnaire for onboarding new customers/counter parties
- SEmploy a list matching software
- Fill out the template on “customer list matching procedure”
- Watch the video “Customer screening: Initial screening and ongoing monitoring
Step 9: Knowing What To Do When Issues Arise
- Fill out the template “internal reporting procedure”
- Watch the video “government reporting”
- Watch the video “Responding to Bank / Headquarters / Insurers Inquiries”
- Watch the video “Licenses”
Step 10: Sanctions Awareness Training for Staff
Show the “Sanctions Awareness” video to others in the company
Step 11: Document Retention
- Watch the video on document retention
- Fill out the template on document retention process
Step 12: Audit of the Sanctions Compliance Program
Watch the video on the audit