Whole of enterprise approach

Companies should adopt an enterprise-wide sanctions implementation system that ideally is integrated into its risk-management. A senior officer with reporting duties to the highest operative level should be in charge of the implementation system, but policies, allocations of resources and funds should be supervised by the highest supervising authority of the company.

Implementation of the following company policy decisions should be supervised::

– Instructions to senior management to institute a corporate UN sanctions implementation program;

– The mandate to periodically brief senior management and the Board about all sanctions compliance measures and any failures, should they occur;

– The authorization combined with clear time-lines, to brief government sanctions supervisory authorities of the relevant governments in cases where violations of UN sanctions are observed or suspected;

-Ensure that enterprise-wide but department-specific implementation guidance is issued for all UN sanctions regimes and measures.

For banks and financial service companies:

– A mandate to file promptly suspicious financial transaction reports with legal reporting obligations, or to law enforcement authorities in cases where the observed activities could be subject to a state’s criminal prosecution.