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FCC Anti-Money Laundering (AML) and Government Sanctions 2026

Fighting Financial Crime: What You Need to Know

Our Strongest Defense: You
Goldman Sachs has strong systems and controls to prevent and detect financial crime. But our people are our best defense. Your actions and good judgment matter most. We all share a commitment to doing the right thing.

What Will This Training Cover?
You already completed the Anti-Bribery and Corruption training earlier this year. This training builds on what you learned there. The training covers two key topics:

  1. Anti-Money Laundering — how to spot and stop potential money laundering
  2. Government Sanctions — rules about who we can and cannot do business with

You will learn how to spot warning signs and report concerns to the Financial Crime Compliance (FCC) team or your division's Compliance team.

Why Does This Matter to You?
It does not matter where you work, what team you are on, or what you do each day. Every employee of the firm is expected to be alert to, and escalate, red flags indicating possible financial criminal activity.

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Defining Financial Crime

What Is Financial Crime?
Financial crime covers a wide range of illegal activities.

Here are some examples of financial crime:

  • Money laundering (hiding illegally obtained money to make it look legitimate)
  • Terrorist financing (providing financing to individuals or groups to facilitate terrorist acts, regardless of whether the money was legally or illegally obtained)
  • Bribery and corruption (offering or accepting improper payments to influence decisions)
  • Fraud (deceiving others for financial, regulatory, or reputational harm)
  • Insider Trading (illegally trading stocks using confidential information for unfair advantage)
  • Market Manipulation (deliberately affecting security prices or market actions to mislead investors for personal benefit)
  • Tax Evasion (deliberately concealing income or falsifying information to avoid paying taxes)

These crimes can be small, like basic theft. They can also be large-scale operations run by organized groups.

Learning Objectives

At the end of this training, you should be able to:

  • Explain key concepts related to AML and Government Sanctions
  • Describe how we comply with AML and Government Sanctions laws and regulations
  • Recognize the requirements of the Know Your Customer (KYC) process
  • Identify red flags of financial crime risk and recognize when and how to escalate
  • Identify types of Government Sanctions and comprehensively sanctioned jurisdictions

Let’s get started.

Know Your Customer (KYC) Basics

Why This Matters
Regulators continue to crack down on financial crime failures. Over the past year, they fined financial firms about $8 billion. These fines targeted firms that failed to meet financial crime rules. The consequences go beyond fines, however. Firms also faced:

  • Caps on assets (limits on how much a firm can hold)
  • Independent monitors (outside experts assigned to watch over the firm)
  • Restrictions on new business (limits on taking on new clients or activities)

Everything Begins with Knowing Your Customer
The people who work closely with clients are the firm's first line of defense. This includes relationship managers and front-office staff.

What Does "Know Your Customer" Mean?
If you work directly with clients, you must:

  • Know who your clients are (understand their background and identity)
  • Understand where their money comes from (learn how they earned their funds and wealth)
  • Monitor their activity (pay attention to the transactions they make through the firm)
  • Watch for warning signs (stay alert to anything unusual or suspicious)
  • Speak up (report any concerns right away through proper channels)

Even if you do not work directly with clients, understanding these basics helps you support the firm's efforts to prevent financial crime.

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Melanie’s Story

Select the arrow on the right to read Melanie’s story.

Melanie was assigned to cover a new client seeking Wealth Management advisory services. Melanie started by gathering some KYC information and learned that the client’s source of wealth came from a family business involved in arms manufacturing.
 

Once activity in the client’s accounts began, it came to her attention that a high volume of wire transfers were being made to a third-party located in Mexico.
 

Melanie recognized the high-risk jurisdiction, so she reached out to the FCC team, who investigated further and identified concerns with the third-party’s business.

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Always Stop and Ask Yourself Three Key KYC Questions

Keep Customer Information Up to Date
The firm needs complete and current information for every client at the outset of the relationship and on an ongoing basis via the Rolling Review program.

The following are three key questions to ask. Select each question to learn more.


  1. Who is the customer?

Stay alert for customers who may pose a higher risk to the firm.

Watch for a customer who:
  • Has negative news coverage, lawsuits, or a history of legal or regulatory problems
  • Has ties to a high-risk country. Always check the firm's country lists (List 3c = high risk, List 4 = highest risk)
  • Has a complicated ownership structure that does not have a clear, legitimate business reason
  • Is a “Politically Exposed Person” a current or former government official, or someone closely linked to one
  • Has unclear or risky sources of wealth. Examples of higher-risk sources of wealth include gambling, cryptocurrency trading, currency exchanges, or cash-intensive businesses


  1. What business does the customer do with us?

Understand what activity you should expect from each customer. Normal activity for one customer may be unusual for another.

Warning Signs
A customer who:

  • Engages in activity that does not match their known wealth, for example, transactions seem too large for their profile
  • Wants to keep transactions secret or asks how to hide activity from regulators
  • Proposes deals that are overly complex and do not make financial sense
  • Exerts extreme pressure to rapidly complete a transaction

Report any of these concerns to FCC or your division's Compliance team right away.


  1. Where did the customer's money come from?

All funds must come from legitimate sources. The customer's stated wealth should match their net worth and account activity.

A customer who refuses to explain where their money comes from is a major red flag that should be escalated.

Be Aware: Watching Suspicious Activity After Onboarding

Your Ongoing Responsibility
Your job does not end after you bring a client on board. You must keep watching their activity for warning signs.

The firm is required by law to detect and report suspicious activity. This includes activity that someone attempted but did not complete.

What Counts as Suspicious Activity?
Watch for any transaction or trade that:

  • May involve criminally derived funds
  • Seems designed to hide where the funds really came from
  • Appear to violate a law or rule — for example, insider trading (trading on secret information) or market manipulation (artificially moving prices)
  • Seems designed to avoid reporting rules — seeks to break transactions into smaller amounts in an apparent effort to evade detection.
  • Does not fit the customer's profile — the activity seems unusual and no one can give a reasonable explanation.

What Should You Do?
If you see any of these warning signs:

  • Escalate right away — report your concern to FCC or your division's Compliance team.
  • Do not tip off the customer — never tell the customer you are reporting them. Doing so may be illegal.

Remember

  • You must monitor activity on an ongoing basis, not just at the start
  • Even attempted suspicious activity must be reported
  • Trust your instincts — if something feels wrong, speak up

More Examples of Suspicious Activity
Here are more examples of customers who may be acting suspiciously.

Unusual Transactions

  • Activity that does not match what you expected based on their profile
  • Moving money in and out quickly without making any trades or investments in between without legitimate purpose

Tax Avoidance

  • Apparent efforts to dodge taxes or avoid reporting under tax transparency rules

Unusual Trading Patterns

  • Trades or profits/loss avoidance that are much larger than normal for the customer’s account
  • Unusual patterns of trading activity (e.g., wash trade)
  • The customer appears to trade using confidential, non-public information (insider trading)

Refusing to share information

  • Reluctance to reveal who controls the account or who benefits from it
  • Evasive or illogical explanations for transactions

Signs of Fraud
Watch for these clues about fraud:

  • Unknown charges appear on a debit card or from checks
  • Emails about transactions contain grammar or spelling mistakes
  • Customer refuses to speak with an advisor
  • New or changed instructions without a good reason
  • Be aware of altered or manipulated documentation

What Should You Do?
If you notice any of these warning signs:

  1. Report it right away
    Contact the FCC or your division's Compliance team

  2. Do not alert the customer
    Never tell the customer you are reporting them

The Bottom Line

Know your client, keep them current, watch relentlessly for red flags, never tip off, and escalate immediately.

Other Financial Crime-Related Risks

Stay alert and aware of evolving risks and potential red flags.

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Significant Financial Crimes

Review the following list of financial crime categories to enhance your understanding and ability to identify associated red flags and potentially suspicious activities.

Select each key financial crime category for its definition.

Money Laundering

Money laundering is the process of disguising the proceeds of criminal activity to make illegally obtained funds appear legitimate. This typically involves concealing the source, ownership, or movement of funds so they can be used for lawful or unlawful purposes.

Certain financial products and markets, such as cryptocurrency or OTC markets, are particularly vulnerable to money laundering due to their speed, anonymity, and global reach.

Terrorist Financing

Terrorist financing involves providing financial support to terrorist organizations or activities. Detection is challenging because funds may originate from both legal and illicit sources and are often used for everyday expenses, such as food or housing, rather than directly funding terrorist acts.

Insider Trading

Insider trading or dealing is the illegal practice of trading financial instruments while in possession of material non-public information (MNPI) that would significantly impact asset prices if disclosed. It includes the unlawful disclosure of such information ("tipping") and the exploitation of a privileged position to gain an unfair advantage over the general investing public.

Market Manipulation

Market manipulation or abuse involves deliberate actions or omissions intended to deceive investors by creating false or misleading signals regarding the price, supply, or demand of a financial product to secure asset prices at abnormal levels and undermine market integrity.

Internal Fraud

Internal fraud refers to acts perpetrated by individuals within the firm, acting alone or with others, through deception, misuse of the firm’s resources, criminal activity, or other intentional acts, omissions, or misstatements —such as stealing funds, hiding losses, or misappropriating firm property — to achieve personal gain or to fraudulently obtain a benefit for the firm or its clients.

External Fraud

Common crimes involving fraud:

  • Account Takeover: Compromise of an account by a fraudster using stolen information, in order to gain access to the victim's funds. This can occur with physically or digitally stolen account credentials.
  • Identity Theft: Identity theft occurs when an individual’s personal identifying information is stolen and used to commit fraud. This may include misappropriating funds from the victim’s accounts or assuming the victim’s identity to obtain financial or other benefits.
  • Vulnerable Adult Fraud: Exploitation of an account belonging to a victim who has a diminished ability to care for themselves. The fraudster will often pose as the victim for financial gain.
  • First-Party Fraud: Fraud events that are facilitated by the account holder themselves, misrepresenting activity on their own account in order to gain or withdraw illegitimate credit or funds.
  • Credential Stuffing: Fraudulent attempt to access multiple accounts using leaked or stolen account credentials, based on the assumption that several accounts may have similar credentials.
  • Malware/Ransomware: Use of malevolent software in order to gain access to login credentials or the account itself. Fraudsters often employ scams to facilitate victims unknowingly installing malware in order to carry out the scheme. Ransomware fraud is a form of malware, where the malevolent software installed by the victim restricts access to the account, demanding ransom for release.
  • Scam: Schemes which deceive the victim through psychological manipulation, such as romance, investment, or impersonation tactics, into willingly releasing funds (i.e., Authorized Push Payment) or credentials.
  • Business Email Compromise: Impersonation of firm personnel, vendors, or trusted parties through compromised or spoofed email accounts to deceive victims into authorizing fraudulent payments or disclosing sensitive information.
  • Money Mule: Individuals who receive and transfer funds connected to fraud or other criminal activity on behalf of others, helping to launder and obscure the proceeds of crime; they may be unwitting participants drawn in through deceptive job offers, romance scams, or other manipulation, or willing participants who move the funds in exchange for a share of the proceeds.

Tax Evasion

Tax evasion is the illegal practice of avoiding taxes by concealing ownership, income, assets, or gains from tax authorities. This may involve complex structures or misrepresentation intended to obscure taxable activity.

Marijuana-related Business

Marijuana is a Schedule I controlled substance under U.S. federal law. The firm generally prohibits transactions, financing, or advisory activities involving U.S. Marijuana Related Businesses (MRBs) or their principals, including trading in certain securities and funds tied to these businesses. Such activities are considered high risk and require Compliance review in accordance with firm policy. Please visit the Compendium for Firmwide and region-specific information on MRBs.

Psychedelics / Psychotropics / Opioids

The firm recognizes increased interest in psychedelics, psychotropics, and other controlled substances. Relationships are generally prohibited where the majority of an individual’s wealth is derived from these substances, as well as investments in companies primarily operating in these industries.

Bribery / Corruption

Bribery involves improperly offering, paying, authorizing, promising, soliciting or receiving anything of value with the intent to obtain or retain business, any business advantage or to influence a government or regulatory action. Corruption can take many forms and is any unlawful or improper behavior that seeks to gain an advantage through illegitimate means or abuse of power for personal gain.

Sanctions Evasion

Sanctions evasion is the deliberate attempt to remove or conceal the involvement of sanctions indicators or touchpoints (e.g., comprehensively sanctioned jurisdictions, entities, individuals) in a transaction or series of transactions to make the transaction(s) appear legitimate.

Modern Slavery and Human Trafficking (MSHT)

Modern slavery refers to the severe exploitation of other people for personal or commercial gain. It encompasses various forms of exploitation, including forced labor, debt bondage, human trafficking, and involuntary servitude, where people’s freedoms and rights are severely restricted.

Human trafficking is the illegal trade and exploitation of humans for the purpose of forced labor, sexual slavery, or commercial sexual exploitation for the trafficker or others. It can involve the recruitment, transport, transfer, harboring, or receipt of persons, often across borders, with the aim of exploiting them for personal or financial gain.

Payments to High-Risk Jurisdictions

Payments involving high-risk jurisdictions carry elevated anti-money laundering risk due to weaker local controls and reduced transparency. These conditions may be exploited to move, layer, or disguise illicit funds, including proceeds of corruption and other serious crimes, increasing potential exposure to money laundering and terrorist financing.

Spotlight on Cryptocurrency

Goldman Sachs provides clearing, settlement, and traditional custody services to Virtual Asset Service Providers who deal in Digital Assets such as Cryptocurrency. While Goldman Sachs maintains high standards on KYC checks, the Virtual Asset Service Providers may not always have the same standards of risk management. This provides an opportunity for money laundering through cryptocurrency for illicit actors.

For example, a cybercrime group successfully launders stolen cryptocurrency through Virtual Asset Service Providers and into Goldman Sachs using the following steps.

Select the arrow on the right to follow the scenario.

The group deposits these funds using fake identities and VPNs, taking advantage of the weak customer screening process at the Virtual Asset Service Provider.
 

The hackers swap stolen tokens across different blockchains and decentralized platforms to make the funds harder to track.
 

The Virtual Asset Service Provider combines the stolen funds with other clean customer money, converts them to cash, and deposits them into its Goldman Sachs accounts to buy U.S. government bonds, thereby making the stolen money look completely legitimate.
 

Key Takeaway: Passing initial onboarding checks may not be enough. Escalate any cryptocurrency touchpoints, digital asset exposures, or Virtual Asset Service Provider relationships to FCC prior to approval. Goldman Sachs must continue to monitor clients after onboarding.

Immediately escalate any subsequent suspicious activity, behavioral anomalies, or risk profile changes to FCC or your Compliance Officer.

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Terrorist Financing

Similar to crypto activities, terrorist financing can be challenging to detect because perpetrators may disguise the proceeds of illegal activity to appear legitimate.

Three indicators of Terrorist Financing
There are three main types of warning signs. Learn to spot each one.

Select each image to view some examples.

Financial Indicators

Watch for unusual money movements, including:

  • Multiple, small transactions that do not match the customer's normal activity, sent to unknown people
  • Multiple transfers in or out with no clear business reason, especially involving areas known for terrorism
  • Payments to organizations where the transaction does not make sense for that organization's stated purpose
  • Transactions with non-profit organizations where the non-profit:
    • Works in or near areas known for terrorism
    • Runs fundraising or operations that lack transparency

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Behavioral Indicators

Watch for sudden changes in how a customer communicates whether online, in person, or by phone. These changes may signal extremist ties when combined with any of the following:

  • Praising violence or extremist beliefs, or celebrating attacks
  • Travel to places where extremist groups operate, and the travel seems unusual for them
  • Calls for violence against individuals, military, government officials, law enforcement, or civilians

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Account Indicators

Watch for suspicious account activity, including:

  • Someone opens an account in the name of a person or group linked to terrorism
  • A customer repeatedly tries to hide who owns the account or who receives the funds, especially when those parties are in or near areas known for terrorism

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Financial Indicators
Behavioral Indicators
Account Indicators

Modern Slavery and Human Trafficking (MSHT)

Select each question to learn more about Modern Slavery and Human Trafficking (MSHT).

How Does Modern Slavery and Human Trafficking
Affect Financial Institutions?

Financial institutions can inadvertently find themselves dealing with or financing human traffickers and modern slavers through several means:
  • Financing companies involved in complex global supply chains, which could indirectly support entities engaged in human trafficking or modern slavery
  • Insufficient or flawed due diligence processes, including lack of disclosure from clients into their operational practices and/or supply chain, which may result in banks unknowingly investing in or financing businesses with ties to exploitative practices
  • Investment in, or the provision of services to, companies operating in emerging or less regulated markets, where regulatory oversight is weaker and there is a broader lack of stringent enforcement of labor standards
  • Dealing with companies who have historical practices or past affiliations with exploitative operations, which could pose reputational risk if not thoroughly investigated

What Are Red Flags for Modern Slavery and Human Trafficking?

Certain behaviors or fact patterns may indicate the presence of individuals engaged in modern slavery and/or human trafficking:
  • Common information (e.g., address, phone number, employment information) used to open multiple accounts in different names
  • Frequent transactions using third-party payment processors that conceal the originators and/or beneficiaries of the transactions
  • Wire transfers to countries with high migrant populations (e.g., Mexico, El Salvador, Honduras, Croatia, Iran, Libya, Sudan, Indonesia, Malaysia) in a manner that is inconsistent with expected customer activity
  • Transactional activity (credits and/or debits) inconsistent with a customer’s employment, business or expected activity, or where transactions lack a business or apparent lawful purpose
  • Deposits or wire transfers are kept below $3,000 or $10,000 in an apparent effort to avoid detection
  • Certain industries are more susceptible to MSHT through exploitive labor practices and involve the hiring of an economically and sociologically vulnerable workforce. Examples include manufacturing/construction, textiles, agriculture, transportation, and food processing

How Do We Protect Against Modern Slavery and Human Trafficking Risks?

Goldman Sachs has a zero-tolerance approach towards MSHT and takes active steps to mitigate and prevent the risk of MSHT, both within firm business and its supply chain. For further information please review the firm’s Statements on Modern Slavery Human Trafficking.

It is our legal obligation to actively prevent any risks of MSHT under the UK Modern Slavery Act 2015 (s.54) and under the Australian Modern Slavery Act 2018 (Cth) (s.13, 14).

Above all, it is imperative to escalate any concerns you may have if you notice any of the red flags presented. Ignoring MSHT red flags can pose significant reputational risks for both the firm and our people.

Spotlight on Failure to Prevent Fraud and Corporate Criminal Liability

The firm may be held criminally liable if its employees, or third-parties, commit a fraud with the intention of benefiting the firm or its clients. In addition, employees, and third-parties may be criminally prosecuted if they commit a related fraud offense.

Review the following information to understand your role in identifying and escalating potentially fraudulent activity to protect yourself and the firm from criminal liability.

Select the arrow on the right for more information.

What Does Internal Fraud look Like?

Fraud is not limited to direct monetary loss. It includes any intentional act, omission, or scheme involving deception, misrepresentation, or concealment of material facts — and extends to the unauthorized acquisition of data or the creation of regulatory or reputational exposure.

Examples of internal fraud may include:

  • Knowingly advising clients to design abusive or illegal tax arrangements
  • Structuring product pricing to include undisclosed fees or charges
  • Failing to log, escalate, or properly investigate customer complaints
  • Hiring candidates to gain business opportunities rather than on merit or qualification
  • Inflating revenue or underreporting/misreporting expenses to meet performance targets or investor expectations
  • Co-mingling client money with the firm’s own funds
  • Concealing material compliance issues
  • Breach of information confidentiality

We hold our people to the highest ethical standards in everything we do and expect all firm personnel to comply with the laws and regulations governing our businesses. This means staying vigilant in your daily activities, adhering to firm policies and procedures, and always acting with integrity and in accordance with our Code of Business Conduct and Ethics.

All firm employees should immediately escalate any concerns related to potential fraud to FCC or divisional Compliance.
 

Fraud Committed by Third-Parties

In addition to fraud committed by its employees, the firm may be held criminally liable for acts performed by third-parties acting for or on behalf of the firm, which may include:

  • Agents, authorized to act on behalf of the firm in specific capacities
  • Third-party providers of outsourced services, for example, fund management services, investor relationship management and any other third-party which provides services to clients on the firm's behalf
  • Contractors or consultants who are engaged to perform a specific project on behalf of the firm
  • Third-parties and intermediaries who perform any distribution or sales services

Preventing fraud is a shared responsibility.
You are expected to maintain a zero-tolerance approach and stay vigilant regarding the third-parties we work with, such as agents, consultants, and outsourced service providers.

If you suspect any deceptive behavior intended to benefit the firm, you must escalate it immediately to FCC or divisional Compliance.
 
 
 

Spotlight on Payments to High-Risk Jurisdictions

The firm identifies certain jurisdictions as high risk (internally referred to as List 4 jurisdictions) because they reflect strategic AML deficiencies that increase our exposure when payments are sent to, from, or through these locations (see the Firmwide Annex on Country Lists. Payments involving high risk jurisdictions may be exploited to move, layer, or disguise illicit funds and therefore warrant heightened attention.

When entering or reviewing payment instructions involving List 4 jurisdictions, the following AML red flags may indicate unusual or potentially suspicious activity and should prompt additional scrutiny:

  • Unclear payment rationale: The stated purpose is vague, generic, or inconsistent with the transaction amount or expected activity
  • Unclear or mismatched parties: Beneficiary or counterparty details do not align with expectations, or third-parties are involved without a clear business rationale
  • Poor-quality payment data: Originator or beneficiary information is missing, incomplete, or inconsistent, or routing appears unusual for the transaction
  • Pressure or avoidance behavior: Requests to bypass controls, urgency inconsistent with the transaction, reluctance to provide support, or attempts to split or retry payments to avoid review
  • Out-of-pattern activity: The transaction does not align with the customer’s typical business activity, geography, or payment behavior

If a single red flag is identified, pause to validate the transaction by confirming details and requesting appropriate supporting information through normal processes.

If multiple red flags are present, or if there are indicators of concealment, evasion, or deception, the activity should be escalated to FCC.

The Bottom Line

Stay vigilant: know your customer, monitor activity, and respect account restrictions. If something feels off, stop, and escalate.

Business and Country-Specific Requirements

The firm’s broader AML Program includes important and targeted content you should know depending on your business area and office location.

By staying informed about business and country-specific requirements, as well as our global firmwide guidelines, we can better navigate the complex regulatory landscape, mitigate risks, and demonstrate our commitment to financial crime compliance.

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Your Business Requirements

If you sit within one of the following businesses, learn about how money laundering risk manifests in your day-to-day operations by reviewing the information for your business.

A downloadable version of these requirements is available for you to reference here.

If you work in a business other than one of those listed here, you can continue with the training.

Select each business to learn more.

Asset Management

Money Laundering Risks: Asset Management

AM-Public (Public Asset Management):

Risk from Third Parties
A large part of AM-Public's money laundering risk comes from third-parties. These include outside distributors and sub-transfer agents (firms that process investor transactions on behalf of a fund).

  • If these third-parties have weak controls, criminals may funnel dirty money into AM-Public's funds.
  • Third-parties may also introduce illegal funds into AM-Public's separate accounts, wrap fee programs, or other advisory programs.
  • These third-parties can block visibility into who the actual investors are.

Risk from Outside Fund Managers

  • Insufficient due diligence on these fund managers may expose the firm to regulatory and or reputational risks.

AM-Private (Private Asset Management)

Risk at Portfolio Companies
AM-Private's biggest risk involves hidden problems at the companies it invests in.

These problems may come from:

  • Companies brought in by related firms or subsidiaries
  • Companies that operate in high-risk countries or industries
  • Companies that lack strong controls to prevent bribery or sanctions violations (breaking rules about doing business with restricted countries or people)

Risk from Investors
AM-Private investors can also pose money laundering risks.

Watch for investors who:

  • Have ties to high-risk countries
  • Are politically exposed persons (current or former government officials, or people closely linked to them)

AM-Private now sells more through third-parties and directly to large institutional clients. This shift increases the risk that criminals may introduce illegal money into AM-Private's accounts.

How to Reduce These Risks
The firm reduces these risks by:

  • Performing thorough background checks on investors, third-parties, and portfolio companies
  • Monitoring portfolio company risks on an ongoing basis
  • Reporting concerns quickly to the right teams

Key Steps for both AM-Public and AM-Private
To protect the firm from money laundering and reputation damage, teams must:

  1. Conduct strong due diligence
    Research customers, third-parties, and portfolio companies thoroughly
  2. Check legal agreements
    Ensure contracts and service-level agreements (written commitments about service standards) have the right protections
  3. Escalate issues fast
    Report any concerns to the compliance team right away

Wealth Management (WM)

Money Laundering Risks: Wealth Management

Choosing and Checking Customers
Picking the right customers and doing thorough background checks are essential. The firm must understand each customer and where their money comes from.

This is especially important for customers who:

  • Have ties to high-risk industries or countries
  • Earn their wealth from high-risk sources

Why Wealth Management Carries Higher Risk
Wealth Management serves customers who may pose greater risk. These include customers who:

  • Are politically exposed persons (current or former government officials, or people closely linked to them)
  • Own bearer share entities (companies where ownership is tied to whoever holds a physical certificate — making true ownership hard to trace)
  • Have complex or unclear ownership structures

These factors raise the risk of:

  • Money laundering (disguising illegal money as legitimate)
  • Tax evasion (illegally avoiding taxes)
  • Handling corrupt or fraudulent funds

Risks from Moving Money
Wealth Management customers often move money in and out of their accounts. These transfers sometimes involve third-parties.

This frequent movement creates a higher risk of:

  • Money laundering
  • Tax evasion
  • Identity theft

Risks from Trading Activity
Some Wealth Management customers may also:

  • Manipulate markets — for example, through microcap fraud — artificially inflating the price of small company stocks
  • Trade on insider information — using confidential, non-public details to gain an unfair advantage

Spotting Suspicious Activity
You must watch for warning signs and monitor accounts on an ongoing basis.

Common Red Flags
Watch for these warning signs:

  • Transaction patterns that look very different from similar customers
  • Sending or receiving money from accounts with no clear connections to them
  • Making unusual trades just before a public announcement
  • Transferring money to or from secrecy havens (countries known for hiding financial information) or other high-risk locations without a clear reason

Consumer

Red Flags in the Consumer Business
Here are common warning signs of suspicious activity from consumer customers.

Unusual Account Activity

  • Money moves through the account very quickly
  • Transfers money to or from secrecy havens (countries known for hiding financial information, such as the Cayman Islands) or other high-risk locations without a clear reason

Suspicious Purchase Patterns

  • Repeated round-dollar purchases with the same merchant in a short time
  • Buying many cashier's checks, money orders, or traveler's checks for large amounts just below a reporting limit

Risks of Cash and Cash Equivalents for Consumer

Generally, the firm does not accept transactions in currency, including coin or paper money from the U.S. or any other country. However, cash equivalents and negotiable instruments may still be used, including:

  • Traveler’s checks
  • Money orders
  • Cashier’s checks and bank drafts
  • Certified checks

Cash-Related Warning Signs

  • Requests for exceptions to the firm’s no-cash deposit policy for Consumer
  • Attempts to make cash deposits
  • Insistence on using only cash-like instruments
  • Receipt of a high volume of cash equivalents, negotiable instruments, or wire transfers that are inconsistent with the customer’s profile

Credit Card and Cash Advance Warning Signs

  • Showing unusual cash advance activity or making large cash payments
  • Watching incoming cash closely. Excessive cash payments often signal money laundering
  • Monitoring credit balance refunds (when overpayments build up and the customer requests refunds). Criminals can use this method to clean dirty money

Cross-Border Warning Signs

  • Making multiple, frequent cash payments or money order payments
  • Sending large wire transfers across borders

GBM-Public (Global Banking and Markets – Public)

Money Laundering Risks:

GBM-Public (Global Banking and Markets — Public)

Key Risks
Insider Trading and Market Manipulation

GBM-Public faces major risks from:

  • Insider trading — using confidential, non-public information to make trades
  • Market manipulation, which involves illegally influencing prices or markets, including:
    • Microcap fraud — artificially inflating the price of small company stocks
    • Wash trades — buying and selling the same security to create fake activity
    • Marking the close — placing trades near market close to manipulate the closing price
    • Price fixing or collusion — secretly agreeing with others to set prices

Investment Advisor Fraud
GBM-Public's Prime Services businesses serve outside fund managers. These managers control investment decisions and fund assets.

This creates a significant risk for:

  • Misappropriation (a manager stealing client funds)
  • Ponzi schemes (using new investor money to pay earlier investors instead of earning real returns)

Identity Theft and Money Laundering
Some Prime Services accounts hold assets on behalf of customers. Money moves frequently through these accounts.

This creates a higher risk of:

  • Fraudulent transactions through stolen identities
  • Money laundering (disguising illegal money as legitimate)

Internal Fraud
Internal fraud can happen in any part of GBM-Public.

Examples include:

  • Mismarking firm positions (recording incorrect values for the firm's holdings)
  • Leaking sensitive information (sharing confidential details with outsiders)

How to Reduce These Risks

Teams must:

  • Verify the identity of fund managers thoroughly
  • Watch for suspicious activity at all times
  • Monitor accounts on an ongoing basis

Red Flags to Watch For
Here are common warning signs of suspicious activity in GBM-Public.

Unusual Transaction Patterns

  • Transaction patterns that look very different from similar customers
  • Money moves through the account quickly with little or no investment activity in between

Suspicious Fund Transfers

  • Sending or receiving money from the same person across different accounts
  • Transferring money to or from secrecy havens (countries known for hiding financial information) or other high-risk locations without a clear reason

Suspicious Trading

  • Making trades that seem unusually well-timed around a major market event

Suspicious Communication

  • Requests to move money urgently from new email addresses or phone numbers

GBM-Private (Investment Banking)

Money Laundering Risks:

GBM-Private (Investment Banking)

Handling Confidential Information
GBM-Private staff regularly receive and handle confidential information. This includes MNPI (important details about a company or deal that the public does not yet know).

Key Risks

  • Protecting MNPI is a major responsibility
  • The firm must maintain information barriers (rules and systems that prevent confidential details from reaching people who should not have them)
  • If someone misuses MNPI, it can lead to insider trading or market manipulation

Corruption Risks
GBM-Private sometimes provides financing or advisory services to government-linked organizations. These include:

  • Central banks
  • Finance Ministries
  • Sovereign wealth funds (government-owned investment funds)
  • Related entities

Some of these organizations operate in countries with higher corruption risk.

What to Watch For

  • Always consider what the financing will be used for (this is critical to reducing risk)
  • Watch for high-risk or hidden third-parties between the customer and a government official or agency
  • A hidden middleman can be a warning sign of bribery or corruption

Money Laundering and Reputational Risks
Some customers may have business models or income sources that raise money laundering concerns. Their assets may be tainted (linked to illegal activity).

How to Reduce These Risks

  • Understand the risk profile of every customer and every party involved in a deal
  • This protects the firm from legal trouble and reputation damage

Customer Onboarding Requirement
You must complete the customer's Know Your Customer (KYC) check (the process of verifying a customer's identity and background) before signing an engagement letter for any deal. Never sign an engagement letter until KYC onboarding is finished.

Global Investment Research (GIR)

Money Laundering Risks: Global Investment Research (GIR)

Main Risk: Access to Secret Information
The biggest money laundering risk in GIR involves MNPI.

GIR also handles price-sensitive information (details that could move a stock price once made public).

How Research Analysts Get Exposed
Research analysts may sometimes access confidential or proprietary information. This can happen in two ways:

  • Through Wall Crossings
    GBM-Private (Investment Banking) staff may ask a research analyst to "cross the wall". This means the analyst temporarily receives confidential deal information about a corporate customer. The analyst must then follow strict rules about what they can and cannot do with that information.

  • Through Firm Information
    Analysts may also see the firm's own private information, such as:
    • Trading positions
    • Trade strategies

Risk During Normal Research
While doing their regular research work, GIR staff may accidentally receive sensitive information. This can come from:

  • Companies they cover
  • Government officials they speak with
  • Other market participants

Key Risks

  • Leaking sensitive information (sharing confidential details with people who should not have them)
  • Insider trading (using secret information to make trades or tip off others)

How to Protect Yourself and the Firm

  • Never share confidential or price-sensitive information with anyone who does not need it
  • Follow information barrier rules at all times
  • Report any concerns right away if you think you received information you should not have

Transaction Banking (TxB)

Money Laundering Risks: Transaction Banking (TxB)

Why Transaction Banking Carries Higher Risk
Transaction Banking offers products and services that involve international transfers and third-party payments. These features create extra risk for money laundering and sanctions violations.

Global Payments Risk
TxB's Global Payments service lets customers send money across borders in different currencies to third-parties.

Why This Is Risky

  • Products that move money across borders carry higher risk than domestic-only products
  • Cross-border transfers increase the chance of sanctions violations (breaking rules that ban certain countries, people, or groups from using the financial system)
  • Third-party payments add extra risk because the firm must also consider the risk of the person receiving the money (not just the customer sending it)

Correspondent Banking Risk
TxB maintains correspondent banking relationships. This means TxB processes transactions on behalf of another bank's customers.

Why This Is Especially Risky

  • TxB handles transactions for people who are customers of the other bank — not customers of our firm
  • TxB does not perform KYC on these underlying customers
  • Despite this, TxB must still prevent and detect criminal activity carried out by those customers through our systems
  • This makes correspondent banking vulnerable to:
    • Money laundering
    • Terrorist financing (sending money to support terrorism)
    • Sanctions evasion (finding ways around financial restrictions)

Regulatory Focus
Regulators pay very close attention to commercial banking and correspondent banking. These areas have faced some of the largest fines and enforcement actions in history.

Requirements for Funds Transfers

What are Funds Transfer Regulations?

  • Funds Transfer Regulations (also called “payment transparency” or the “travel rule”) require key debtor and creditor information to accompany certain payments to help prevent and detect financial crime.
  • They are implemented through local laws and through payment rail or scheme rules, so required fields and message formats can differ by payment type.
  • They support sanctions screening and AML monitoring by improving identification of the debtor and creditor and enabling investigation when needed.
  • Required debtor and creditor data is captured at payment initiation, transmitted through the payment message where the rail supports it, and retained in a usable form.
  • Controls focus on completeness, accuracy, and usability of debtor and creditor data for screening and monitoring.
  • Responsibilities are shared across the payment chain based on role (for example, initiating, receiving, or intermediary institutions) and rail capabilities.

What Does This Mean at the Firm?
The firm applies the Funds Transfer Regulations globally across all its offices and subsidiaries. It covers:

  • Wire transfers
  • Electronic bank transfers
  • Virtual asset transfers (digital currency transactions)

Rules for Outgoing Payments

  • Outgoing payments are monitored to confirm required transparency data is present and usable, an example the underlying client name and address if applicable
  • If required information is missing or unusable, the payment is held for repair or rejected
  • If optional information is missing, the firm may request enrichment or apply proportionate controls

Rules for Incoming Payments

  • Incoming payments are monitored where applicable to confirm party information supports screening and monitoring
  • If expected information is missing or unstable, the firm takes reasonable steps to remediate and escalates where suspicious
Who is Responsible?
Team Role
Business units (First Line of Defense) Enter accurate payment data
Corporate Treasury Run day-to-day payment controls
Financial Crime Compliance team
(Second Line of Defense)		 Provide oversight and review

Record-Keeping

  • The firm must keep detailed records of all Travel Data
  • These records allow the firm to quickly rebuild payment details if a regulator asks for them

What Happens If a Partner Institution Doesn't Comply?
If another financial institution repeatedly fails to provide the required Travel Data, the firm may:

  • Limit the relationship, or
  • End the relationship entirely

Refer to this policy for more details: Firmwide Standard on Global Funds Transfer Regulation Requirements.

Your Country Requirements

In addition to firmwide global requirements, country-specific regulations also apply and must be understood.

If you reside, provide support to, or do business in any of the jurisdictions listed here, select that location and familiarize yourself with the country-specific information. If you do not reside, provide support to, or do business in any of the jurisdictions listed below, you can continue past this section of the training.

Once you have read the information provided, close out of the PDF and find the course window in your browser to continue with this training.

EU Anti-Money Laundering Reform: What You Need to Know

What Is Changing?

  • From 10 July 2027, the EU AML package introduces a single Anti Money Laundering Regulation (AMLR), replacing divergent national AML transposition regimes.
  • Establishment of a new EU level supervisor, the Anti Money Laundering Authority (AMLA).
  • Shift from nationally driven approaches to a uniform EU wide supervisory and enforcement model.

What Will AMLA Do?

  • Direct AML supervision of selected obliged entities.
  • Indirect oversight of national competent authorities supervising other obliged entities.
  • Central coordination of supervisory standards, onsite inspections and thematic reviews, and enforcement expectations across the EU.

What Does This Mean for Our Firm?

  • Increased harmonization of AML/CFT requirements across EU jurisdictions.
  • Reduced national discretion in interpretation and application of AML rules.
  • Stronger group wide accountability for AML/CFT governance across EU entities and branches.

Australia

Belgium

Cayman Islands

China

Czech Republic

Denmark

France

Germany

Greece

Hong Kong

Indonesia

Ireland

Italy

Japan

Korea

Kuwait

Luxembourg

Mexico

Monaco

Netherlands

New Zealand

Poland

Qatar

Romania

Saudi Arabia

Singapore

South Africa

Spain

Sweden

Switzerland

Taiwan

United Arab Emirates

United Kingdom

The Bottom Line

Stay updated on your business and local requirements, spot red flags early, and escalate immediately.

Sanctions

Sanctions take many different forms and include many countries. They are constantly evolving and require us to be vigilant as conditions across the world change.

Scroll down to continue.

Government Sanctions: What You Need to Know

Why Sanctions Exist
Governments and international groups (like the United Nations) use economic sanctions to protect national security and advance foreign policy goals.

Sanctions prevent international bad actors from accessing assets and financial services.

Select each question to learn more.

What sanctions does Goldman Sachs adhere to?

The firm follows sanctions from multiple sources, including:

  • Governments: United States, European Union, United Kingdom, Canada, Japan, Singapore, and others where local law requires it
  • International bodies: United Nations and similar organizations

Why Should This Matter to You?

Financial firms sit on the front line of enforcing these rules. When you follow sanctions rules, you directly help protect national security and foreign policy goals.

Sanctions can affect many parts of our business, including:
  • Clients and their true owners (the people who ultimately own or control a company)
  • Counterparties (the other side of a transaction)
  • Guarantors and signatories (people who guarantee or sign off on deals)
  • Collateral (assets pledged to secure a loan or deal)
  • Issuers of securities (companies that create stocks, bonds, or other financial products)

The firm will not take part in any prohibited transaction, either directly or indirectly, that involves:

  • Any person or company on a sanctions list
  • Any person or company located in a comprehensively sanctioned country or region
  • Any deal that supports business for, with, or on behalf of sanctioned countries or regions

Your Role

  • Know the rules. Understand that sanctions apply to every part of our business
  • Stay alert. Watch for any signs that a transaction may involve a sanctioned person, company, or country
  • Speak up. Report any concerns to the Financial Crime Compliance team right away
  • Never tip off a client or counterparty about sanctions reviews or reports

Your actions help the firm stay on the right side of the law and support global security.

Types of Government Sanctions

Economic sanctions come in different forms. They generally fall into three categories.

Select each image to learn more about each economic sanctions category.

Comprehensive Sanctions
List-Based Asset Freeze Sanctions
Capital Markets Restrictions

Comprehensive Sanctions

These are the broadest types of sanctions. They block most firm activity that involves a comprehensive sanctioned country or region.

This includes activity that is:

  • Directly or indirectly tied to the government of that country
  • Connected to any person living in that country
  • Linked to any company based in or created under the laws of that country

In short: The firm cannot do almost any business with these countries.

List-Based Asset Freeze Sanctions

These sanctions target specific people and companies involved in illegal activities.

  • Governments and international groups create lists of sanctioned individuals and companies.
  • The firm cannot do any business with anyone on these lists.
  • If a person or company appears on a sanctions list, the firm must freeze their assets (hold their money and block all transactions).

In short: The firm checks every client and counterparty against these lists before doing business.

Capital Markets Restrictions

These sanctions limit certain financial activities tied to specific countries and sectors.

They currently apply to parts of the economies of:

  • Russia
  • China
  • Belarus
  • The Government of Venezuela

If any transaction or firm activity may involve a company or sector covered by these restrictions, you must send it to the Financial Crime Compliance team for review.

In short: Do not move forward with these transactions on your own. Always escalate.

Comprehensive Sanctions: A Closer Look

This is the first and broadest type of sanctions. Here is what you need to know.

Which Countries and Regions Are Comprehensive Sanctioned?
The firm cannot do almost any business with the following places:

  • Crimea (a region of Ukraine)
  • "Donetsk People's Republic" and "Luhansk People's Republic" (regions of Ukraine)
  • Cuba
  • Iran
  • North Korea

These are the current comprehensive sanctioned countries and regions.

What About Russia, Belarus, and Venezuela?

  • Russia, Belarus, and Venezuela face many types of sanctions.
  • However, they are not comprehensively sanctioned countries.
  • Different rules apply to them. Always check with the Financial Crime Compliance team before doing business tied to these countries.

What About Syria?

  • The government removed comprehensive sanctions on Syria in 2025.
  • However, several people, companies, and groups linked to Syria still appear on sanctions lists.
  • The firm must still freeze their assets (hold their money and block transactions).
  • The firm still treats Syria as a high-risk country for money laundering and corruption.

In short: Syria is no longer comprehensive sanctioned, but it still carries serious risk. Stay cautious.

What You Should Do

  • Never do business with comprehensive sanctioned countries or regions without approval.
  • Always check if a client, company, or deal has ties to any of these places.
  • Treat Syria with caution. The rules changed, but risks remain.
  • Ask the FCC team if you are unsure about any country or transaction.

Spotlight on Russia

What Happened?
In February 2022, Russia invaded Ukraine. In response, several governments launched broad and complex sanctions against Russia.

These governments include:

  • United States
  • United Kingdom
  • European Union
  • Other countries around the world

How Do These Sanctions Affect the Firm?
The Russia sanctions touch every part of the firm. They affect:

  • Russian clients
  • Global banks and market systems
  • Companies that issue stocks and bonds
  • Other parties the firm does business with

In many cases, the firm must block (freeze) assets. This means the firm must hold the assets and stop all transactions tied to sanctioned people or companies.

What Controls Does the Firm Have?
The firm uses tools and checks to spot and stop banned activity. For example, the firm screens for restricted Russian securities (stocks and bonds the firm cannot trade).

However, these controls cannot catch everything. You play a key role too.

What You Should Do

  • Watch for red flags: If you notice any possible links to a sanctioned person or company, act right away.
  • Ask before you act: If you are unsure whether a deal or activity is allowed, do not move forward on your own.
  • Escalate immediately: Report concerns to any of the following:
    • Your manager
    • The FCC team
    • Your divisional Compliance team
  • Check the latest guidance. Review the firm's most recent Russia-related rules and updates.

List-based Asset Freeze Sanctions: How They Work

This is the second type of sanctions. These sanctions target specific people and companies — not entire countries.

Select each image to learn more about list-based asset freeze sanctions.

What Activities Do These Sanctions Target?
Which Countries Do These Sanctions Cover?
What Must the Firm Do?
What Is the Process for Raising a Concern?

Governments place people and companies on sanctions lists when they are involved in illegal or harmful activities, such as:

  • Criminal organizations that operate across borders
  • Human rights abuses and corruption
  • Drug trafficking
  • Cybercrimes (crimes committed using computers or the internet)
  • Rough diamond trade (trading uncut diamonds linked to conflict)
  • Terrorism
  • Weapons spreading (helping banned weapons reach dangerous groups)

Sanctioned people and companies can be based anywhere in the world. This includes countries most people consider low risk, like Canada and the United Kingdom.

Here are some countries and regions where list-based sanctions currently exist:

Afghanistan Hong Kong Somalia
Balkans Iraq South Sudan
Belarus Lebanon Sudan and Darfur
Burma Libya Syria (former Assad Regime)
Central African Republic Mali Venezuela
Democratic Republic of Congo Nicaragua West Bank-Related Sanctions
Ethiopia Russia Yemen

Important: Just because a country has a list-based program does not mean the entire country is comprehensively sanctioned. However, there may be other restrictions on government officials, companies, or specific industries in that country.

The firm:

  • Must block (freeze) any assets connected to a person or company on a sanctions list.
  • Cannot release those assets unless:
    • The government lifts the sanctions, or
    • The government gives specific permission to release them

Are these countries also high-risk?

  • Countries with list-based sanctions are often high-risk for other types of financial crime.
  • Even if a country is not comprehensively sanctioned, the firm may still face extra restrictions on deals with that country's government, officials, or certain industries.

The firm uses screening tools to catch sanctioned names. But these tools cannot catch everything.

If you notice any possible link to a sanctioned person or company, take action right away:

  • Tell your manager
  • Contact the FCC team
  • Reach out to your divisional Compliance team

Do not wait. Report your concern even if you are not sure. It is always better to ask than to miss something.

Capital Markets Restrictions

This is the third type of government sanctions. These sanctions limit specific financial activities tied to certain countries.

Select each location to see examples of its capital markets restrictions.

Russia
Venezuela
China
Belarus
What You Should Do

Russia

The expanded sanctions from 2022 target many parts of the Russian economy, including:

  • Energy
  • Defense
  • Technology

What Do These Restrictions Mean?

  • The firm generally cannot trade or deal in new or existing stocks and bonds from Russian companies.
  • These rules affect any company that operates in Russia or derive most of its revenue from Russia.

What You Should Do

  • Always escalate any Russia-related exposure to your manager, the Financial Crime Compliance team, or your divisional Compliance team.

Venezuela

The firm treats Venezuela as a high-risk country for money laundering and corruption.

What Do These Restrictions Mean?

  • The U.S. government has frozen the assets of the Government of Venezuela and its agencies. This includes PdVSA (Venezuela's state-owned oil company).
  • Venezuela is not a comprehensive sanctioned country.
  • The firm may allow some transactions in securities issues by the Government of Venezuela in accordance with established guidelines.
  • U.S. sanctions on Venezuela continue to evolve, and the U.S. government has issued some authorizations primarily focused on the Venezuelan oil, gas, and mining sectors.

What You Should Do

  • Escalate any possible connection to the Government of Venezuela or its agencies, and/or any new proposed activity with touchpoints to Venezuela, to your manager or Compliance.

China

What Do These Restrictions Mean?

  • U.S. sanctions ban buying or selling publicly traded securities of companies the U.S. government labels as Chinese Military-Industrial Complex companies (CMIC).
  • The firm and its U.S. clients cannot make new investments in these companies' securities.
  • This ban also covers exchange-traded funds (ETFs) (funds that hold a basket of stocks and trade on an exchange) and mutual funds that include CMIC securities.

What You Should Do

  • Always ask your manager or Compliance before doing any business with a CMIC company.

Belarus

What Do These Restrictions Mean?

  • The European Union has frozen the assets of specific people and companies in Belarus.
  • EU sanctions also include capital markets restrictions tied to the Government of Belarus.
  • The EU has placed import and export bans on certain goods from Belarus, such as:
    • Petroleum products (oil-based fuels and materials)
    • Potash (a mineral used in fertilizer)

What You Should Do

Never trade restricted securities without Compliance approval.

Escalate immediately if you spot any link to these countries in a transaction.

Ask questions first. Contact your manager, the FCC team, or your divisional Compliance team before acting.

What You Should Do

Never trade restricted securities without Compliance approval.

Escalate immediately if you spot any link to these countries in a transaction.

Ask questions first.
Contact your manager, the FCC team, or your divisional Compliance team before acting.

Jo’s Story: A Real-Life Sanctions Breach

This true story shows what can go wrong when a team misses sanctions warning signs.

Select the arrow on the right to read Jo’s story.

What Happened?
At a previous company, Jo's team handled a transaction with a client linked to Venezuela.

The Team's Mistake

  • The team did their background checks on the client.
  • They found the client had ties to Venezuela. This raised a warning sign.
  • However, the team knew Venezuela is not comprehensively sanctioned like Cuba or North Korea.
  • They approved the transaction.

What They Missed

  • The client was majority owned by the Government of Venezuela.
  • The Government of Venezuela is on an asset freeze list.
  • This means the firm may have had an obligation to freeze the client's assets and should not have approved the deal without a detailed review by Legal and Compliance.
 

What Happened Next?

  • The client's bank blocked the first payment.
  • The bank reported the transaction to the regulator (the government body that oversees financial rules).
  • The regulator investigated Jo's company.
  • The regulator found the team missed clear warning signs when they first brought the client on board.
 

The Consequences

  • The company received a multi-million dollar fine.
  • The fine led to budget cuts.
  • The incident affected the company and Jo personally.
 

Key takeaway:

  • Governments expect firms to look closely at transactions that might try to get around sanctions.
  • Always examine complex ownership structures. A client may look safe but could be owned by a sanctioned party.
  • Asset freeze sanctions can apply to specific people and companies — even in countries that are not comprehensively sanctioned.
  • When in doubt, escalate. Talk to your manager or the Compliance team right away.
 
 
 

Higher Risk Commodities and Sanctions

Certain goods carry a higher sanctions risk. The risk depends on three things:

  • Where do the goods come from?
  • Who is involved in the deal?
  • How are the goods shipped?

Why Are Commodities Risky?
Ownership and Shipping Risks

  • Some trades require the firm to own or physically hold goods
  • Those goods could come from a sanctioned country
  • The goods could pass through a sanctioned country during shipping
  • Sanctioned ships or aircraft could carry the goods

Counterparty Risks

  • The buyer, seller, or their clients could be sanctioned by people or companies
  • Always check who you are dealing with before moving forward

Shipping Risks

  • Hundreds of ships and shipping companies appear on sanctions lists
  • The firm must carefully monitor all shipping activity
  • Watch for shipments that use a sanctioned vessel or shipping company
  • Also watch for goods that pass through a sanctioned country on the way to their destination

Example of Higher Risk Commodities

Let’s look at some examples of commodities derived from sanctioned countries.

Select each image to learn more about the commodities.

Metals

Aluminum

  • Certain brands of aluminum are produced in Iran and Russia

Nickel

  • Certain brands of nickel contain Cuban-origin nickel (e.g., Sherritt, a Canadian entity) or nickel produced in Russia

Copper / Cobalt

  • Certain brands of copper or cobalt are produced in Russia

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Fuel and Crude Oil

These are commonly produced in:

  • Russia
  • Iran
  • Syria
  • Venezuela
  • Cuba

go to next button

Potash
  • Belarus is the world's second-largest producer of potash (a mineral used in fertilizer)
  • The European Union bans imports from Belaruskali, the state-owned producer in Belarus

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Metals
Fuel and Crude Oil
Potash

The Bottom Line

Before you trade: investigate, screen every name, trace every route, and escalate.

The Sum of It

It’s almost time to test what you have learned in this training. But before you go, let’s take a moment to reflect on the key takeaways of this training.

Scroll down to continue.

You Are Our Best Defense

  • Take onboarding and KYC seriously, but don’t stop there. You must continuously monitor client activity for any red flags.
  • Ensure that client KYC information remains current and is refreshed in accordance with the firm’s “Rolling Review” program.
  • Do not reveal any potential suspicions you may have to your client – doing so could give rise to a violation of law that prohibit “tipping” off the client.
  • Escalate any red flags to FCC or divisional Compliance.
  • Sanctions are dynamic and they change quickly. Report potential sanctions risks quickly to your manager, the FCC team, or divisional Compliance.

Our Shared Responsibility

Stay sharp, spot the red flags, and speak up. Protecting the firm starts with you.

Sanctions Change Quickly

Sanctions shift fast and ignorance is no defense. When in doubt, escalate.

Sanctions Come in Different Forms

From comprehensively sanctioned countries to frozen assets, sanctions take many forms. Know them all, because you are the firm’s best defense.

Scroll down to continue.

Sarah Chen, a successful business owner, approaches the firm's Wealth Management division to open an account. She meets all client criteria and has been assigned a Private Wealth Advisor. During the onboarding process, Sarah mentions that she recently sold a large commercial property in a country known for higher corruption risk. She wants to transfer the sale proceeds into her new account immediately.

As the Wealth Management professional handling her onboarding, what is the most appropriate course of action?

Select the best response and then select Submit.

Please only use the tab and shift tab keys to access each option and the Submit button with the keyboard. Then only use the Enter or Space key to select an option or the Submit button with the keyboard. The up and down arrow keys are not fully supported. If the screen reader suggests that you use the arrow keys to change an option, please ignore this. Continue using the tab and shift tab keys and then Enter or Space keys to change an option. If you stop hearing the screen reader use the tab key to reset the focus.

Submit

Meridian Holdings, a long-standing client, has always maintained steady and predictable account activity. Over the past three weeks, the firm's monitoring system flags a sharp spike in incoming wire transfers. The transfers come from multiple shell companies registered in a jurisdiction known for strict banking secrecy and weak rules on revealing true owners.

Meridian Holdings describes the payments as "advisory fees," but the amounts far exceed what the company typically earns based on its known business and public financial records. When the relationship manager requests supporting documents about the services provided and the source of funds, the client provides vague responses, pushes back on the requests, and insists the firm handle the matter with "maximum confidentiality" due to "sensitive business arrangements."

As the professional responsible for this client relationship, what is the most appropriate course of action?

Select the best response and then select Submit.

Please only use the tab and shift tab keys to access each option and the Submit button with the keyboard. Then only use the Enter or Space key to select an option or the Submit button with the keyboard. The up and down arrow keys are not fully supported. If the screen reader suggests that you use the arrow keys to change an option, please ignore this. Continue using the tab and shift tab keys and then Enter or Space keys to change an option. If you stop hearing the screen reader use the tab key to reset the focus.

Submit

Sam, a trader in GBM-Public, receives a call from Marc Settle, a long-time client who holds positions in several illiquid bonds. Marc expresses concern because there has recently been a surge in selling activity for one of these bonds, which is driving down its value and putting pressure on his fund. Shortly after Marc’s call, another investor who holds the same bond contacts Sam and asks him to sell off their position as well.

Sam contacts Marc to gauge his interest in purchasing the bonds, given Marc’s prior involvement. Marc responds by requesting that Goldman Sachs “help his fund out” by acquiring the bonds from the other client and then reselling them to him at a price well above the current market value. He tells Sam, "I need the bond prices to reach a specific level in the market by the end of the quarter," and asks Sam to call him once he has secured the bonds. The conversation ends abruptly.

Which of the following represents the complete correct answer?

Select the best response and then select Submit.

Please only use the tab and shift tab keys to access each option and the Submit button with the keyboard. Then only use the Enter or Space key to select an option or the Submit button with the keyboard. The up and down arrow keys are not fully supported. If the screen reader suggests that you use the arrow keys to change an option, please ignore this. Continue using the tab and shift tab keys and then Enter or Space keys to change an option. If you stop hearing the screen reader use the tab key to reset the focus.

Submit

Lisa Park, a Private Wealth Advisor, receives an urgent email from a long-standing client, Mr. David Grant, requesting an immediate wire transfer of $2.3 million to a bank account in a country where Mr. Grant has no known business or personal ties. The email states the transfer is for a "once-in-a-lifetime real estate deal" that must close by end of day.

Lisa notices several unusual details: the email contains spelling mistakes Mr. Grant never makes, it lacks his usual formal greeting, and it includes a PDF attachment labeled "Deal Summary" that appears poorly formatted with a generic logo. Mr. Grant typically calls Lisa directly for large transactions and follows up with a signed letter of authorization.

As the advisor responsible for this client's account, what is the most appropriate initial action Lisa should take?

Select the best response and then select Submit.

Please only use the tab and shift tab keys to access each option and the Submit button with the keyboard. Then only use the Enter or Space key to select an option or the Submit button with the keyboard. The up and down arrow keys are not fully supported. If the screen reader suggests that you use the arrow keys to change an option, please ignore this. Continue using the tab and shift tab keys and then Enter or Space keys to change an option. If you stop hearing the screen reader use the tab key to reset the focus.

Submit

Rachel, a junior trader on the equities desk, overhears a phone conversation between two senior bankers in the elevator. They discuss a confidential, unannounced takeover bid where "Pinnacle Ltd." plans to acquire "Summit Corp." at a 40% premium to the current share price. Later that afternoon, Rachel purchases a large number of Summit Corp. call options through her personal brokerage account. After the deal becomes public two weeks later, Rachel sells the options for a significant profit.

Which of the following best describes the primary concern with Rachel's actions?

Select the best response and then select Submit.

Please only use the tab and shift tab keys to access each option and the Submit button with the keyboard. Then only use the Enter or Space key to select an option or the Submit button with the keyboard. The up and down arrow keys are not fully supported. If the screen reader suggests that you use the arrow keys to change an option, please ignore this. Continue using the tab and shift tab keys and then Enter or Space keys to change an option. If you stop hearing the screen reader use the tab key to reset the focus.

Submit

Upon reviewing onboarding documents provided by a prospective PWM client, you notice the prospect is a Russian and UK national living in Dubai. He is a finance professional who held senior roles at multiple institutions prior to those institutions being designated by OFAC, OFSI, and EU. The prospect himself is not sanctioned by any competent authority. The prospective client’s source of wealth primarily derived from his employment, as well as having real estate investments in Russia.

What action should you take?

Select the best response and then select Submit.

Please only use the tab and shift tab keys to access each option and the Submit button with the keyboard. Then only use the Enter or Space key to select an option or the Submit button with the keyboard. The up and down arrow keys are not fully supported. If the screen reader suggests that you use the arrow keys to change an option, please ignore this. Continue using the tab and shift tab keys and then Enter or Space keys to change an option. If you stop hearing the screen reader use the tab key to reset the focus.

Submit

A client based in Luxembourg wants to transfer a portfolio of securities from another financial institution to the firm. The portfolio includes securities issued by institutions that are located, operate, and derive majority revenue from Russia. The client assures you the securities are not subject to sanctions restrictions and promises to bring in a lot of future business if you can make the transfer happen.

Which of the following actions should you take?

Select the best response and then select Submit.

Please only use the tab and shift tab keys to access each option and the Submit button with the keyboard. Then only use the Enter or Space key to select an option or the Submit button with the keyboard. The up and down arrow keys are not fully supported. If the screen reader suggests that you use the arrow keys to change an option, please ignore this. Continue using the tab and shift tab keys and then Enter or Space keys to change an option. If you stop hearing the screen reader use the tab key to reset the focus.

Submit

Attestation

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FCC Anti-Money Laundering (AML) and Government Sanctions 2026

FCC Anti-Money Laundering (AML) and Government Sanctions 2026

Below are the topics that will be covered in this learning. You must advance through each topic in order, but you can select the Home button if you would like to view this Homepage or revisit a specific topic.

If you require any kind of assistance or accommodation in order to complete this training, please contact Compliance Learning.

Fighting Financial Crime: What You Need to Know

Know Your Customer (KYC) Basics

Other Financial Crime-Related Risks

Business and Country-specific Requirements

Sanctions

The Sum of It

Test Yourself

Attestation

 

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