Sanctions & Embargoes Training Case Study

Sanctions & Embargoes Training
UK Headquartered Global Bank

Gracechurch’s Head of Training Services was engaged by a UK  headquartered global bank, with operations in over 70 Countries, to lead in the design and execution of an extensive Global sanctions training programme, as part the Bank’s response to a Deferred Prosecution Agreement (DPA).

The resulting three year programme successfully delivered;

• Annual adaptive, mandatory Sanctions awareness training for the bank’s 270,000 staff, across all operating locations, in 14 different languages;
• Annual Sanctions and Anti-Money Laundering classroom based training for front office staff in sanctions high risk roles (requiring the classification of all of the Bank’s roles in respect of sanctions risk);
• Annual bespoke knowledge assessments, measuring staff learning in order to inform future business educational requirements and ultimately remedial actions for persistent failure.

To ensure the sanctions training solutions were persistent and also cost effective; face to face training was delivered, through an industry recognised “train the trainer” programme, to the bank’s in-house sanctions experts, successfully equipping them to execute all future specialist training to the sanctions high risk audience.  

In addition, the Gracechurch Head of Training Services represented the bank in all sanctions training related interactions with the in-house compliance monitor, appointed by the US Authorities.  

Ultimately, the success of the sanctions programme was seen as a critical consideration in the dismissal of the DPA.