Trade Compliance,

Sanction Program and

Product Compliance

Management Team

Pricer AB
April 2024
 TRADE COMPLIANCE
Areas Involving Pricer
Operations

 Classification
 Duties
 Certifications
 Product Testing
 Country of Origin
 Trade Risks
 Self Evaluation
 Sanctions Screening
 Export Control

Source: ICC International Chamber of Commerce. 2024

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 PRODUCT COMPLIANCE

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 TRADE COMPLIANCE
WHAT CAN HAPPEN IF THINGS GO WRONG?
OFAC Sanctions breach EU Commission to
Barclays pays up $2.5mn can lead to 30 years of define as crime the
for Zimbabwe sanctions Imprisonment if having violation of sanctions
breaches prior knowledge of with imprisonment up to
infringement 5 years

Ford Motor Company to

Commerzbank AG pays
settle USD 365M for Swedbank Latvia settled
$1.45bn penalty
customs penalties for US3,430,900 for OFAC
Iranian transactions
misclassify and Sanctions violation
sanctions breach
undervalue

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 WHAT ARE
SANCTIONS
& EXPORT CONTROLS

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HOW DOES THE WORLD LOOKS LIKE FOR
SANCTIONS?

Europe, Russia, Central Asia, Middle East / 2024

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HOW DOES THE WORLD LOOKS LIKE FOR
SANCTIONS?

Latin America Africa

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WHAT TO DO??
Create and follow the Conduct adequate due
Sanctions Program – is a diligence so you don’t do
must have for any EU business with designated
Operator persons

Screen all countries

where you have business, Follow up on any
all entities, customers, matches against the
partners and individuals Sanctions Lists (UN, US,
in line with your EU)
procedures.
Freeze any continuity in
doing business with any
Report any knowledge or
identified match
suspicion of breaches
belonging to a sanctioned
promptly
country, entity or
individual

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 Management Directive to introduce the
Sanctions Program importance of compliance for the
Implementation company and the business. Promote
ACTIONS buy-in among leadership.

Sanctions Screening Sales, Operations, Finance departments to

implement sanction screenings procedures

Risk Assestment & Due Continuously evaluate regions, counterparties,

Dilligence and customers to detect potential sanctions
risks as operations, sanctions laws, and
sanctions lists evolve.

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 Reporting Hot Line Introduce compliance hotline for
employees to report potential breaches,
questions or request support
ACTIONS
Promote information, trainings,
Training raise awareness through intranet news,
mandatory trainings

Restrict business if matches are found.

Act on Red Flags Appoint responsible business leader to
Ensure checks are done before deals are closed.
No circumvention is allowed.

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WHAT NOT TO DO??
 Do NOT enter into any business, financial or trade activity with a designated person or a
sanctioned regime.
Do NOT conduct any business that you willingly know, or suspect it will breach sanctions
Do NOT circumvent systems designed to detect sanction breaches – ei.
Stripping out or changing a name
Advising a customer on how to do so or channelling transactions via another party
Do NOT Ignore any match that’s flagged up or suspicious match
Report any suspicious activity
( NOTE: There is anonymous compliance channel / add link)

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The KEY is the Compliance Culture
• Management Commitment by providing adequate attention and mandate to follow sanctions program
• Ensuring that all departments have Sanctions screening integrated into their processes
• Providing sufficient guidance and cascade down the tone
• Give adequate support to the Compliance team and personnel in the implementation of policies

The Lock is Processes Implementation and Risk Monitoring

• Settle responsibilities and accountability for sanctions compliance in every organization
• Screen the obligations, transactions and business opportunities against the Sanctions Listings
• Support the continuous improvement in Trade Compliance activities

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