When asked the likelihood of undertaking planning to enter the Cuban market, nearly half (44%) of survey respondents said they are very likely or somewhat likely to. One bright spot appears to be the opportunities presented by renewed relations between the United States and Cuba. 5: Are there any bright spots in the sanctions environment-opportunities companies should be aware of? Only about half of respondents indicated that board members receive training financial services firms, however, are more likely to provide such training to the board. Three-quarters or more of survey respondents indicated that their company provides sanctions training to compliance personnel, front-line personnel and senior management. 4: Where else can companies create value by investing in their sanctions compliance programs? ”And with many companies expanding, innovating and entering into more complex transactions, companies are continuing to call on systems, processes, controls and people to be as efficient and cutting edge as possible,” she adds. “Keeping up with evolving sanctions regimes and performing appropriate due diligence of customers, vendors, distributors and other third parties remains critical,” notes Wendy Schmidt, a Deloitte Advisory principal with Deloitte Financial Advisory Services LLP. Data is much more likely to be a top challenge for financial services (42%) and large companies* (42%) than for non-financial (24%) or for smaller companies (29%). When asked what their most difficult challenge is regarding sanctions compliance, executives most often cited data quality (35%) and screening customers and transactions (28%). 3: What other challenges do companies face in managing their sanctions compliance programs? To address this, executives indicated that the areas receiving attention within their sanctions compliance programs are automated screening systems (35%) and conducting more thorough customer due diligence (30%). Nevertheless, keeping up with changes to OFAC sanctions programs and sanctions against specific industry sectors are most frequently cited as concerns by the senior executives who responded.
ALISON CLEW UPDATE
2: Facing increased compliance costs, what are sanctions compliance program priorities today?Īccording to the survey results, most companies (75%) assess and update their sanctions compliance programs annually or more often.
“If you agree with the respondents’ prediction that costs will continue to rise, then spending strategically is key-while each company’s priorities may be unique, improving data quality and implementing screening solutions comprehensively will typically provide additional confidence to any company’s sanctions compliance program,” says Alison Clew, a Deloitte Advisory principal with Deloitte Transactions and Business Analytics LLP.
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