White paper

See what the FCA’s 2026 sanctions assessment and OFAC’s enforcement record reveal about emerging regulatory expectations and the growing role of AI in building more effective sanctions controls.

Sanctions compliance expectations are converging. The FCA’s 2026 assessment of more than 150 supervised firms identified persistent weaknesses across governance, risk assessment, screening, alert management, evasion detection and breach reporting – many of the same issues highlighted by OFAC through years of guidance and enforcement action.

This white paper explores the emerging global standard for effective sanctions compliance, the practical implications for financial institutions, and how AI-enabled technology can help institutions strengthen controls, respond to evolving threats and demonstrate effectiveness.

What you’ll learn

Explore the key findings and implications for sanctions compliance:

  • Regulatory convergence – understand where FCA findings and OFAC expectations align, and what this means for institutions operating across jurisdictions.
  • Critical control gaps – examine weaknesses across screening, alert management, governance, risk assessment, evasion detection and trade sanctions.
  • The AI imperative – discover how AI can strengthen screening, prioritize alerts, identify complex networks and evasion patterns, and support trade document analysis.
  • A framework for action – identify priority areas for gap assessment, remediation and technology investment to build a more effective sanctions compliance program.

Download the white paper to understand the converging regulatory standard and how your organization can prepare.

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A Convergent Standard for Sanctions Compliance FAQs
What are the FCA’s expectations for sanctions compliance in 2026?

The FCA expects firms to demonstrate effective governance, granular risk assessments, well-calibrated screening, timely alert management, robust evasion controls and clear breach reporting procedures. Firms should also evidence that their sanctions controls work effectively in practice.

How do FCA and OFAC sanctions compliance expectations compare?

FCA and OFAC expectations increasingly converge around senior management accountability, risk-based controls, effective screening, testing and assurance, training, and documented governance. Together, they point towards a common standard for effective sanctions compliance across jurisdictions.

What are the most common weaknesses in sanctions screening?

The FCA identified issues including poor matching of name variations, non-Latin characters and unusual formatting, as well as list-management errors and inadequate oversight of third-party screening technology. Its testing found identification rates fell from 90% for exact matches to 75% for name variations.

How can AI improve sanctions compliance?

AI can improve sanctions compliance through advanced name matching, intelligent alert prioritization, network and beneficial-ownership analysis, evasion detection, trade-document analysis and continuous regulatory intelligence. These capabilities can help firms identify risks that traditional screening and manual processes may miss.

How should financial institutions strengthen sanctions compliance?

Financial institutions should prioritize screening calibration and assurance, alert management, more granular risk assessments, trade sanctions controls, evasion typologies and breach reporting. The white paper also recommends structured gap assessments supported by measurable remediation plans.

about the author
Elizabeth Callan
AML | FinCrime | Sanctions Compliance & Risk Management SME

Elizabeth has spent more than 20 years tackling money laundering (ML) and financial crime. At SymphonyAI she drives the strategy and innovation that delivers transformational compliance solutions. Prior to SymphonyAI she worked within the U.S. intelligence and law enforcement communities. As a Senior Intelligence Analyst with the U.S. Department of the Treasury, she drove U.S. policy and enforcement actions and supported U.S. officials and policymakers, including at OFAC and FinCEN, on ML threats and sanctions initiatives. She also served as Treasury’s first Intelligence Liaison and Senior Advisor to DEA’s Special Operations Division, spearheading large-scale ML investigations and intelligence collection initiatives, training law enforcement agents and analysts, and promoting collaboration between Treasury and U.S. and foreign law enforcement. In the private sector, Elizabeth also worked within financial institutions and consulting managing investigations teams, developing risk management strategies for complex products and services, and designing institutional AML programs and controls. Elizabeth also teaches AML and sanctions courses at the university level.

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