Sanctions & Embargoes Case Study

Sanctions & Embargoes
UK Headquartered Global Bank

The Retail Division of a UK Headquartered Global Bank engaged one of the Gracechurch Co-Founders, with the objective of initially establishing and subsequently operating, both customer and payment sanctions screening controls.

The three year, £50m, change programme, delivered comprehensive solutions (people, process, technology, governance) which were widely considered at the time to be best in class.

As a direct result of the success of these implementations, the Gracechurch Co-Founder was retained to assist with the Bank’s response to concerns raised by US Authorities in respect of potential historic violations of OFAC Sanctions.

The first phase of the response required the coordination of a seven year retrospective review of the Bank’s customer relationships and US$ denominated, cross border payments. The review was predicated on the rapid deployment of bespoke screening capabilities, and the establishment and training of a team of 100+ alert investigators.
The resultant findings from the retrospective review formed the basis of the Bank’s self-disclosure to US Authorities. The Bank’s rapid disclosure, and high degree of cooperation during this discovery phase was cited by the US Authorities as a mitigating factor in the subsequent financial settlement.  

The second phase of the response required the Gracechurch Co-Founder to incept and direct a programme to standardise customer and payment sanctions screening controls across all of the Bank’s Divisions, globally.

This £20m programme successfully migrated all of the Bank’s screening activities to the customer and payment screening solutions previously created for the Retail Division, and also introduced cultural matching techniques in time for consideration by US Authorities in the pending settlement.

The Gracechurch Co-Founder was further retained to coordinate all of Bank’s mandated responses under the subsequent Deferred Prosecution Agreements (DPA) and Cease and Desist Order (C&D). Specifically, the creation of a robust and persistent Global Sanctions Control Programme, delivery of sanctions training for all members of staff, creation of role specific annual sanctions training, and the implementation of an annual Sanctions Risk Assessment.  The speed and quality of the Bank’s fulfilment of their legal obligations resulted in the DPA being dismissed at the earliest legally permissible opportunity.

In addition to all of the above, the Gracechurch Co-Founder also coordinated the first two annual inspections of the Bank, as required under the C&D, and managed through to successful closure all of the findings that were raised.