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Article July 13, 2026

Why Wider Risk Thinking is Required to Meet Sanctions Demand

Why Wider Risk Thinking is Required to Meet Sanctions Demand

Center for Financial Professionals

Sanctions risk can no longer be managed in isolation as geopolitical volatility, fragmented regulation and increasingly sophisticated financial crime create interconnected challenges across financial institutions. A senior banking executive argues that fi

Financial institutions must stop treating sanctions as a standalone compliance issue and instead embed them within a broader enterprise-wide non-financial risk framework if they are to keep pace with an increasingly volatile geopolitical environment.

That was the central message from the head of risk and quality at a European banking group, who argued that sanctions have become one of the clearest examples of how interconnected risks now demand coordinated governance, consistent data and integrated risk management across organizations.

"The speed and complexity of evolving risks means we need to adapt our risk management frameworks just as quickly," he said.

Drawing on recent geopolitical developments, the speaker explained that sanctions regimes are changing at an unprecedented pace, leaving firms with little opportunity to rely on static controls or historical assumptions.

"It used to be we asked what the next jurisdictional issue might be," he said. "Now the question is what happened last night, or what might happen later this week."

That acceleration is being driven by a combination of geopolitical conflict, increasingly fragmented sanctions regimes and rapidly evolving policy decisions.

Rather than relying primarily on multilateral sanctions, governments are increasingly deploying unilateral measures that differ significantly between jurisdictions, creating additional complexity for global financial institutions.

The executive pointed to diverging definitions of ownership, control and reporting requirements across countries as examples of the growing challenges facing internationally active banks.

"Gone are the days when the sanctions regime was largely the UN and OFAC," he said. "More jurisdictions now have robust sanctions regimes, and firms need to understand which ones apply to them."

The result is a far more demanding operating environment, particularly as sanctions increasingly overlap with other forms of financial crime.

Trade-based money laundering, proliferation financing, terrorist financing and fraud often share similar characteristics, making it increasingly difficult to categorize suspicious activity into a single risk discipline.

"If you only approach it by asking whether it's sanctions, that's the wrong question," he said. "You've identified a potential risk. Now you need to determine what it actually is."

That interconnectedness reinforces the need for firms to dismantle organizational silos. According to the speaker, sanctions cannot be managed effectively without close coordination between financial crime teams, operational risk, governance, technology, data management and third-party oversight.

He argued that fragmented governance remains one of the industry's greatest vulnerabilities.

"It all starts with governance," he said. "You set up the framework, the committees, the reporting structure and the principles. Then you make sure people follow them."

Central to that governance is what he described as a clear enterprise strategy supported by explicit risk appetite statements that define precisely which jurisdictions, products and customer relationships an institution is prepared to support.

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