Screening for sanctions...?
Discussion
Renewing indemnity insurance for a small engineering consultancy. Had a lovely set of ambiguous questions sent by the broker this morning, including:
"Please confirm the procedures you employ to monitor and screen for sanctions."
Not had this question put to me before and the current policy has no requirement for checking for sanctions
- it isn't something that I look at on an even monthly basis... However, apart from checking the UN/UK Gov sanctions list for each of our clients, what constitutes a procedure, or even a sufficient check?
Any others had experience with this?
"Please confirm the procedures you employ to monitor and screen for sanctions."
Not had this question put to me before and the current policy has no requirement for checking for sanctions
- it isn't something that I look at on an even monthly basis... However, apart from checking the UN/UK Gov sanctions list for each of our clients, what constitutes a procedure, or even a sufficient check? Any others had experience with this?
It's not well known at all that everyone has to comply with sanctions, even if you aren't regulated or a business. Of course, it depends what the sanctions actually are, and OFSI aren't going to be actively interested in what smaller firms are doing.
There's some helpful guidance on the OFSI website if you are interested (I don't work for them btw!)
There's some helpful guidance on the OFSI website if you are interested (I don't work for them btw!)
I have seen this before. It relates to the sale of things to countries where the UK government restricts what can and can't be sold by British companies to certain countries for varying reasons.
Compliance really is a simple case of availing yourself of the latest list of sanctioned countries and what goods apply done through subscribing to the 'Noticed to Exporters' published by the Government: https://www.gov.uk/government/collections/notices-...
Fines and penalties are very high for companies that ignore or circumvent sanctions.
Compliance really is a simple case of availing yourself of the latest list of sanctioned countries and what goods apply done through subscribing to the 'Noticed to Exporters' published by the Government: https://www.gov.uk/government/collections/notices-...
Fines and penalties are very high for companies that ignore or circumvent sanctions.
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