Christian Focacci on Sanctions, Data and Vetting Third Parties [Podcast]

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Post By: Adam Turteltaub

Keeping up with the latest sanctions requirements is very difficult. Names of individuals and organizations are added and removed frequently, and there are multiple prohibited persons and entities lists to track. The US Office of Foreign Asset Control (OFAC) list is but one of several to consult, and just because a company isn’t on the US list doesn’t mean it’s not on the list of another country that can claim jurisdiction over your organization.

So how do you determine who you can do business with? Christian Focacci, Vice President of Offering Management at Steele suggests in this podcast you begin with an appreciation of the challenges of data and determining the risk: is this an entity I need to know everything about or which only requires a cursory assessment?

The answer to that question will determine how much research you need to do. But even that is only a start. For example, hen reviewing news sites, especially outside of your own country, it’s important to assess how reliable that source is. And, while machine learning offers advantages, it’s far from perfect and human judgement is most definitely still needed.