Common sanctions compliance trip points from 2023 enforcement cases

Complying with the increasingly complex sanctions landscape is demanding firms expand their management of risks beyond annual, list-based assessments of potential entanglements with known sanctioned entities and the companies they own.

More and more, thanks to pressure from regulators and Western governments, companies must understand not just whether they are directly doing business with a sanctioned individual or company—they also must recognize the ever-changing tricks and sleight of hand used by sanctioned entities to access Western markets by adjusting their internal controls accordingly.

“A lot of banks and companies are struggling with the unprecedented rate of sanctions being implemented,” said David Lynch, global head of analytical solutions at Sayari, a commercial risk intelligence platform. “A manual, list-based approach won’t keep up, and it’s easy to inadvertently miss doing business with sanction-linked entities. Understanding broader networks of sanctioned entities and high-risk enablers is crucial to effectively mitigating risk that may otherwise remain hidden.”