A Convergent Standard for Sanctions Compliance
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.
Related resources
Infographic - FinCEN's 2026 AML/CFT Program Reform and Section 314(b) Update
Webinar - Is the Risk-Based Approach Broken? Reinventing FinCrime Compliance for a Dynamic Threat Environment
White Paper - Navigating the Delayed FinCEN Investment Adviser AML Rule
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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.
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.
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.
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.
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.
Elizabeth Callan is a recognized leader and innovator in the fightagainst money laundering and financial crime with 25 years of experience acrossintelligence, law enforcement, and the private sector. At SymphonyAI, she is atthe forefront of redefining the future of financial crime compliance and riskmanagement. She drives strategy and innovation, developing groundbreakingAI-led, intelligence-driven solutions that are transforming how globalinstitutions detect, disrupt, and prevent money laundering, sanctions evasion,and other sophisticated financial crimes. Her work is helping to shift theindustry approach from reactive, technical compliance to proactive, risk -aligned, and highly effective risk management. Prior to SymphonyAI, Elizabethserved in the U.S. intelligence and law enforcement communities. As a SeniorIntelligence Analyst at the Central Intelligence Agency and the U.S. Departmentof the Treasury, she shaped high-impact U.S. policy and enforcement actions —including Section 311 designations — while directly advising senior officialsacross the USG, including at OFAC and FinCEN, on critical threats and nationalsecurity strategies. She also served as Intelligence Liaison and Senior Advisorto the DEA’s Special Operations Division, where she led complex, large-scalemoney laundering investigations, enhanced intelligence collection efforts,trained law enforcement agents and analysts, and forged strong internationalpartnerships. In the private sector, Elizabeth has held leadership roles in financialinstitutions and consulting firms, where she built and managed investigationsteams, designed robust AML and sanctions programs, and developed riskmanagement strategies for complex products and services. A recognized subjectmatter expert, Elizabeth teaches AML and sanctions courses at the universitylevel. She holds a master's degree in economics and analytics and ACAMS’Advanced Certification in Financial Crimes Investigations (CAMS-FCI).