Risk Intelligence
A rapidly evolving sanctions landscape doesn’t need to become a compliance headache. Discover how the right solutions can keep you ahead of an evolving sanctions compliance curve.
- Explore key OFAC screening requirements for banks, why it matters and what happens if you fail to comply.
- Uncover best-practice approaches for better screening.
The sanctions landscape is highly dynamic and, in 2025, this landscape appears more uncertain than ever. Our Global Sanctions Index (GSI) report provides a detailed account of the key changes in global sanctions over the past year, as well as insights into the most important mega-trends – including uncertainty – that will shape sanctions in the coming months.
In particular, uncertainty will be a core characteristic of the sanctions landscape for the foreseeable future, and it seems possible that there will be even more divergence – hyper-divergence – if the geopolitical realignments that now seem possible come to fruition.
LSEG report – The Global Sanctions Index (GSI): A lens on worldwide sanctions
Despite the sheer volume of sanctions, their dynamic nature and this overlay of uncertainty, remaining sanctions compliant doesn’t need to be a compliance headache. Guidance, hands-on help and tech-enabled solutions are available to help.
Key requirements for effective compliance
In the US, the Office of Foreign Assets Control (OFAC) administers and enforces sanctions. In 2019, the office published ‘A Framework for OFAC Compliance Commitments’, providing guidelines around sanctions compliance.
The framework is intended for use by organisations subject to US jurisdiction and foreign entities doing business with the US[1] and delivers some key information to help you remain compliant with evolving sanctions obligations.
It also encourages organisations to develop, implement, and routinely update a risk-based sanctions compliance programme (SCP)[2], but what are the core elements you need to consider when implementing such a programme?
Here is a snapshot of some key considerations:
Screening
Screening of both customers and transactions is vital – and is an important first step in ensuring that you do not transact with any individual or entity on a Specially Designated Nationals and Blocked Persons List (SDN list). Effective screening in turn relies on the right data, so you will need reliable access to accurate, up-to-date sanctions data.
Enhanced due diligence (EDD)
Where screening identifies heightened potential risk, further investigations in the form of EDD may be necessary. EDD delivers a “full picture” and can include uncovering the ultimate beneficial owners of entities, understanding the source of wealth of individuals, and much more.
Effective EDD delivers detailed insights and background checks – and is designed to deliver deep intelligence where heightening risk is suspected or detected.
Transaction monitoring
Robust transaction monitoring should capture comprehensive data, especially about cross-border transactions – including sender and receiver details, transaction amounts, currencies and transaction purposes – to help you uncover potential links to sanctioned individuals or entities.
Staying on the right side of the compliance curve
Complying with sanctions is non-negotiable – failure to do so can have far-reaching consequences, from restrictions on trading to asset freezes, and from hefty fines to potentially substantial reputational damage, which can have a lasting impact on your brand.
Operational disruptions are another key consideration. Investigations and enforcement actions can disrupt day-to-day operations.
In extreme cases, violations can even lead to criminal charges, with the potential for imprisonment.
Staying on the right side of the compliance curve is essential. The right screening programme can help you stay compliant and deliver some immediate benefits.
Screening as a competitive advantage
Screening can help you pinpoint potentially illicit activity quickly. It can also help you flag areas where you need to gather additional insights to ensure that you are not doing business with sanctioned entities or individuals.
This in turn helps to mitigate the risk of non-compliance with global regulations, minimises the chance of financial loss and protects you from potentially severe reputational damage.
Screening can be so much more than a compliance necessity, however. When you approach screening in an intelligent, strategic way, you can turn it into a competitive advantage – one that boosts your efficiency and delivers a smooth, seamless customer experience.
Here are three top tips to for better screening:
Three tips for better screening
The right technology
Technology is essential for the efficient screening of customers and transactions. Manual processes can be prone to human error and slow the pace of business, potentially leaving you non-compliant with sanctions regulations. Automated screening adds immediate benefits: it improves accuracy, streamlines processes, reduces delays and delivers a better customer experience.
Education and training
The role of ongoing education and training should not be underestimated. Best practice involves training employees on regulations, procedures and risk mitigation on a continual basis. The sanctions landscape is highly dynamic, so once-off training is not enough – rather regular guidance is needed as sanctions requirements evolve.
Audits and reviews
Regular reviews and audits can help you to ensure that you are compliant, but can also offer opportunities for improvement. For example, a thorough review of your processes around vendor risk assessments can help you measure the effectiveness of your screening programme, as well as flag areas for potential improvement.
As the sanctions landscape continues to evolve in 2025, take the right steps now to implement a proactive – and effective – sanctions compliance programme.
To find out more about how you can stay compliant and turn screening into a competitive advantage, see our suite of screening solutions.
About the GSI
The Global Sanctions Inflation (GSI) Index takes its base as January 2017 (=100) and includes every explicit sanctions regime tracked by LSEG World-Check Risk Intelligence data, covering all keywords with the ‘sanctions’ keyword type. This means that implicit sanctions, for example, sanctions created by the OFAC 50% rule, are entirely excluded from this analysis. The sanctions regimes tracked are very broad. The consequences or severity of the sanctions are not considered.
While divergence has been a trend for several years, we may now be entering a period of hyper-divergence, especially given that the future of American sanctions on Russia is “uncertain at best”, while several other sanctions bodies, including those in the EU and UK have strengthened both sanctions and enforcement against Russia.
If diverging views grow more pronounced, we could see the mega-trend of divergence morph into a new trend – hyper-divergence. Watch this space.
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