A Sanctions Policy is an internal document that sets out the rules and standards to which staff must adhere to prevent breaches of national and internal legislation on sanctioned countries, persons, entities, goods and services. All staff must be made aware of the policy contents to ensure an understanding of the current risks and the controls in place to mitigate them.
This Sanctions Policy template is provided in Word format over 9 pages and 2,687 words. Elements in [square brackets] require editing to make it specific to your organisation.
Design is based on financial services organisations globally and covers the following aspects:
1. Policy Statement
2. Scope
3. Minimum Standards
3.1 Sanctions
3.2 Risk Assessment
3.3 List Management
3.4 Sanctioned Countries
3.5 Business Relationships
3.6 Payments
3.7 Filtering System
3.8 Dual Use Goods
4. Governance
4.1 Roles and Responsibilities
4.2 Training and Communication
4.3 Compliance Monitoring and Review
4.4 Reporting and MI
4.5 Escalations
5. Records and Retention
6. Contacts