Building Sanctions-Ready Compliance Programmes

Malcolm Wright, Shyft Network, led a discussion on the industry’s role in the crisis, and what actions might be taken. Panellists included Elaine Sun, Huobi, Bill Hughes, ConsenSys, Liat Shetret, Solidus Labs, and Che Sidanius, Refinitiv. 

Key considerations for the industry: 

  • Start with the competency of your team. Professional knowledge is key to supporting exchanges with their requirements. 
  • Some exchanges have set up tools to automate updates of sanctions lists, which can be updated on an hourly basis. 
  • The scale and complexity of these sanctions is unprecedented. This is a systemic problem, not a crypto-specific one: there are 65 different sanctions authorities, with 300 different sanctions lists, all with different naming conventions. Consider outsourcing capabilities to a screening provider to avoid false positives, and stay on top of the quality of the data. 
  • Stay focused on on-ramps and off-ramps. Look to better share information with traditional finance service providers on the nexus points between fiat and crypto
  • Find teams who will advise you on your minimum legal requirements on a global scale. You need to know not only your own requirements, but those of the jurisdiction that your client is from. 
  • The industry needs to focus on solutions that implement controls by turning law language into technical language. 

Watch the full panel session here.