Inside the Sanctions Maze: Why Compliance Starts With Knowing Your Business

In an era defined by geopolitical volatility, Max Lerner, Managing Director and Global Head of Sanctions Compliance at State Street Bank, emphasizes that sanctions compliance isn't just about policies—it's about partnership. The key, he argues, lies in knowing your business as deeply as you know the regulations. Without that foundational understanding, compliance becomes guesswork.

Lerner traces the evolution of sanctions from 2018 through to the sweeping 2022 Russia programs, underscoring the critical role of executive-level buy-in and surge response teams. These task forces, formed in moments of global tension, help elevate sanctions compliance from a regulatory chore to an organizational priority. But the real challenge isn’t just implementing new sanctions—it’s staying ahead of the ever-evolving evasion tactics.

Criminal networks, he notes, are well-funded and persistent, constantly recycling and refining old tactics to slip through the cracks. While no institution can catch everything, the goal is to catch enough—and to file timely suspicious activity reports (SARs) that feed into larger investigations. In this way, financial institutions act as intelligence nodes, contributing fragments of insight that regulators and law enforcement piece together into action.

On the tech front, Lerner cuts through the hype around artificial intelligence. Most current applications branded as AI are really process automation tools. The true value lies in redeploying human expertise—freeing up compliance professionals from repetitive tasks so they can focus on nuanced risk analysis and cross-border complexities.

When it comes to navigating divergent global regulatory landscapes, Lerner stresses structure: robust governance, well-defined committees, and consistent dialogue with teams around the world. But above all, success depends on compliance officers being able to speak the language of the business. Sanctions knowledge is table stakes. Translating that knowledge into real operational guidance is what sets strong programs apart.

As Lerner concludes, industry events remain crucial—not just for learning, but for networking. The value, he says, lies in peer insight and the informal knowledge-sharing that happens long after the conference ends.