The FIFA World Cup Qatar 2022™ just like every mega-event is going to be a spectacular sports gala with 32 participating countries drawing in supporters from around the world. It is estimated that over a million people will visit Qatar to tour, trade, and enjoy the largest international football tournament. While this is exciting news for business owners as well as fans, the sudden spike in the movement of people and goods for this event exposes both companies and individuals to higher risks of denied party screening and compliance violations.
Qatar is the smallest country to ever host a World Cup, a competition which attracts millions of attendees from the soccer community including sponsors, partners, and spectators. The limited accommodation and surging prices mean people will look for alternative options outside of the country and travel in for the games. The pressure on limited travel options will mean a busy time for airlines and Private Jet Charters.
What Does the Sanctions Compliance Landscape Look Like for Private Jet Charters?
The charter ban imposed on Russian entities by the United States, United Kingdom and European Union have taken a broad, varied, and complex scheme with fast changing regulations and strict enforcements.
In March 2022, the U.S. Federal Aviation Administration issued an order that essentially closed U.S. airspace to Russian entities including private citizens and dual citizenship holders but it soon after amended it to focus on only Russian nationals who are on the International Trade Administration list. The aviation sanctions levied by the EU still applies to Russian passport holders even if they are dual citizens.
In a move to strengthen its aviation sanctions, the UK has pushed forward legislation to criminalize non-compliant private jet owners and operators. The former UK foreign minister Liz Truss said, “Banning Russian flagged planes from the UK and making it a criminal offence to fly them will inflict more economic pain on Russia and those close to the Kremlin”. To further cripple air travel, the UK government in May banned Russian owned carriers from selling unused landing slots at UK airports.
These dynamic aviation sanctions regimes call for enhanced denied party screening and deeper visibility into the compliance risks facing private jet charters.
What are the risks of Denied Party Screening Gaps?
If found non-compliant, operators can lose their license in addition to paying fines. Owners can also have their jets impounded, and in the case of the UK which has moved to criminalize sanctions compliance breaches, offenders could be jailed.
In March, a Russian national chartered a private jet and the pilots, passengers and jet owner were detained by Canadian authorities. Amongst themselves, they were fined almost $20,000. The UK government also seized a private jet breaching Russian sanctions at one of its airports.
Following the sanctions on Russian entities and their owners the European business trade body, the Air Charter Association warned members, “Where a company or other body corporate has committed one of these offences, individual company directors and other senior officers/managers can also be convicted of the same criminal offence.”
It is every organization’s legal obligation to comply with the relevant sanctions in all the jurisdictions in which it operates. They should be screening against relevant denied party lists to minimize exposure to the risk of compliance violations.
Denied Party Screening and Compliance is at the forefront of the World Cup
As demand for private jets are projected to surge during the world cup season, the associated pressure from the volume of transactions is expected to put a strain on the compliance processes of private jet charters, even where internal controls exist, you may find the constraints on time drive personnel to rush through sanctions screening requirements, making more errors in identifying false negatives thus increasing the risk of organizations.
However, this is a time when compliance due diligence must be enhanced. Restricted parties are aware that sporting events like these create the sort of opportunities where lapses and screening deficiencies allow them slip through the system. Robust denied party screening systems are necessary to ensure aviation sanctions evaders do not undermine the compliance position of private jet charters.
FIFA itself has put into place strong compliance procedures taking due diligence seriously and carrying out detailed checks on third parties. Aircraft manufacturers are also screening to prevent sales to sanctioned oligarchs especially with many aircrafts owned or controlled by Russian nationals.
No company big or small should jeopardize its reputation and business continuity—especially Private Jet Charters who operate in a highly regulated environment with dire consequences. Should a sanctioned passenger or crew member be found on board your flight you risk being turned away, in addition to fines, loss of licenses, and jet seizures. Descartes has the compliance tools that can provide the level of due diligence and denied party screening required, including specialist lists that can help identify potentially risky parties and entities that threaten compliance with aviation sanctions.
Why use Descartes Denied Party Screening solution?
Descartes Visual Compliance is a leading provider of sanctions screening solutions including automated and dynamic denied party screening, export compliance, and other 3rd party risk management solutions. For over 35 years, our solutions have helped organizations streamline and simplify their sanctions compliance function in an ever-changing, risk laden regulatory environment.
The Descartes Denied Party Screening software has the capabilities to carry out in-depth ownership chain analysis and passenger checks to ensure no sanctioned individuals board your flight. It performs real-time screening as part of standard workflows and integrates seamlessly with major ERP, CRM, and other business management systems.
To help you build an effective denied party screening compliance process, we have collected the following resources:
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