Sectoral compliance guidance

Once a corporate board of directors has decided to enable an enterprise-wide UN sanctions compliance system and create a senior management position to coordinate and oversee its implementation, practical steps have to be taken by a number of corporate divisions and affiliates and suppliers. The parties that will be involved, to various degrees, in a corporate group’s sanctions implementation effort typically include:

  • Heads of all business sections and affiliates
  • Legal counselors for all departments and subsidiaries;
  • Shipping and export licensing specialists
  • Contracting and subcontracting departments
  • Operational and physical security services
  • Human resources departments
  • Bookkeeping, financial controllers
  • Travel agents
  • External legal advisors
  • Strategic business planners and facilitators
  • External suppliers and partners
  • Security advisors and risk assessment providers
  • Recruitment services

For most of these internal and external interlocutors, it may not be necessary to go beyond participation in periodic awareness raising programs. The key actors that deal with compliance and legal affairs, shipping, contracting, security, human resources and bookkeeping should be kept closely involved with regular updates and advisories about evolving compliance requirements. These tasks must be planned and coordinated by the senior sanctions compliance manager and he or she must also receive prompt notices from the corporate implementation network about any developments that could expose the company to risks. The following corporate sanctions implementation model illustrates communication and monitoring tasks the compliance manager must oversee: