Sanctions Risk Management

Is your organisation prepared for increased enforcement and stricter penalties? Advisense provides end-to-end support to ensure full sanctions compliance, from comprehensive gap assessments to the implementation of screening frameworks and targeted training programmes.

Sanctions Risk Management

Sanctions Compliance  

Until recently, the lack of EU-wide minimum standards for prosecuting sanctions violations has contributed to fragmented enforcement. The EU and UK’s commitment to rigorous sanctions enforcement is now reshaping the compliance environment. As supervisory bodies intensify their activities and harmonisation measures take effect, the financial and reputational cost of non-compliance will only rise.     

The New Regulatory Landscape

In addition to existing UN sanctions and OFAC regulations, sanctions compliance requirements have increased substantially. The 18th EU sanctions package (July 2025), sets out common definitions of criminal offenses and penalties for breaches of EU sanctions law. The sanctions scope has expanded more, and the deadline for the EBA Guidelines on Restrictive measures is set to 31 December 2025 with no extension. In the new sanctions risk reality, plausible deniability is replaced by the standard awareness of probability of circumvention and further includes secondary sanctions.  

The EBA Guidelines explicitly address sanctions evasion and emphasize the use of advanced screening systems, data quality management, and geolocation/proxy detection to help prevent indirect or disguised attempts to bypass sanctions. With this comes a specific focus on governance. Senior management and compliance officers are tasked with overseeing frameworks designed to identify and mitigate both compliance and evasion risks. 

Sanctions Compliance as a Core Element of Your Risk Management Strategy

Recent court decisions demonstrate that violations of EU and UK sanctions can result in severe penalties, including substantial fines, asset confiscation, and prison sentences for individuals. There is a clear trend towards more aggressive enforcement, and the risk of non-compliance is higher than ever.  

With enforcement on the rise and the legal framework tightening, companies are advised to prioritize sanctions compliance as a core element of their risk management strategy: 

  • Review and update internal policies and training to reflect the latest legal requirements. 
  • Calibrate your screening system and make sure due diligence on business partners and transactions is thorough enough to prevent third party sanctions exposure. 
  • Keep pace with evolving EU and national sanctions enforcement trends. 
  • Seek expert guidance to address complex challenges and equip your teams with the knowledge and tools needed to stay ahead in an evolving sanctions environment. 

Advisense 360 Degrees Sanctions Compliance

Sanctions Scope – Exposure Assessment & Risk Mapping 

Ensure complete insight into your sanctions exposure across all jurisdictions, products, and third parties. Recommended for organisations needing baseline assessment, annual risk reviews or an informed second opinion. 

What You Get: 

  • Complete mapping of applicable sanctions regimes (UN, EU, OFAC, UK) 
  • Sector-specific risk analysis including dual-use goods and technology transfers 
  • Third-party and supply chain vulnerability assessment 
  • US nexus evaluation (USD transactions, US persons, US technology) 
  • Evasion and circumvention pattern analysis 

Deliverables: 

  • Regulatory gap analysis against EBA Guidelines 
  • Executive risk heat map with a Board-ready exposure report 
  • Recommendations on prioritized remediation roadmap 

Timeline: 2-3 weeks  

Screening Optimisation & Analytics 

Are you swamped with false positives while genuine sanctions exposures slip through? Transform your existing screening from noise to intelligence. Advisense screening optimization and analytics suite is optimal for companies struggling with alert volumes or outdated screening. 

What You Get: 

  • Deep-dive analysis of your current screening performance 
  • Data analytics to identify pattern-based false positives 
  • Rule optimization and threshold calibration for your system 
  • Whitelisting strategies and better filtering logic 
  • Enhanced matching algorithms within your existing platform 

Deliverables: 

  • False positive reduction roadmap (typically 50-70% reduction) 
  • Optimized rule sets for your screening system 
  • Custom filtering logic and exclusion lists 
  • Quality metrics and performance benchmarks 
  • Monthly optimization reviews and adjustments 

Timeline: 4-6 weeks implementation  

Governance & Program Design 

Can you demonstrate a mature, risk-based sanctions governance to regulators? We help you build a sanctions program that meet current and future regulatory requirements, whether you are building from scratch or need to make sure you stand regulatory scrutiny. 

What You Get: 

  • Complete policy and procedure framework oversight 
  • Roles and responsibilities matrix (Three Lines of Defence) 
  • Risk appetite statement and tolerance levels 
  • Board and senior management oversight structure 
  • Integration with AML/CTF framework or standalone design 

Deliverables: 

  • Full policy suite aligned with EBA Guidelines requirements 
  • RACI matrices and governance charts 
  • Risk appetite framework 
  • Board training materials 
  • Annual review calendar 

Timeline: 4-6 weeks  

Alert Management & Case Resolution 

How much time do you spend investigating false positives instead of real threats? Teams are often overwhelmed by alert volumes or lacking investigation structure. Advisense can help you move from 100 alerts to 10 real risks with a secure and very hands-on process. 

What You Get: 

  • Deep-dive analysis of alert triage and risk scoring 
  • Investigation playbooks and decision-trees 
  • Graph analytics for complex relationship discovery 
  • Case management workflow optimization 
  • Evidence packaging for regulatory reporting 

Deliverables: 

  • Streamlined investigation procedures 
  • Automated decisioning for low-risk alerts 
  • Investigation toolkit and templates 
  • Quality assurance framework 
  • Productivity metrics and KPIs 

Timeline: 3-4 weeks  

Compliance Dashboard 

What does your command centre for sanctions compliance control look like? Advisense can work with you to establish real-time visibility, proactive control and custom dashboards with KPIs aligned with your risk appetite. 

What You Get: 

  • Live Risk Monitoring: Track exposure changes as they happen 
  • Predictive Analytics: Identify emerging risks before they materialize 
  • Regulatory Tracking: Stay ahead of new sanctions packages and requirements 
  • Board-Ready Reporting: Clear, visual insights for senior management 

Deliverable:  

Training & Capability Building

Does your team have the skills to identify and respond to current and future sanctions risks? Advisense provides tailored training program for rapid upskilling or maintaining cutting-edge capabilities. We help you transform your team into the sanctions experts you need. 

What You Get: 

  • Regulatory update workshops 
  • Role-based training programs 
  • Evasion and circumvention pattern recognition 
  • Investigation skills development 
  • System and tool optimization training 

Deliverables: 

  • Customized training curriculum 
  • Board awareness sessions (1-3 hours) 
  • Deep-dive specialist programs 
  • E-learning/Webinars 

Timeline: Ongoing/regular or concentrated bootcamps 

Contact us to learn more about how we can support you.

Sweden

Norway

Louise Brown

Director

Carl Olsson

Head of Advisory & Head of Advisense, Norway

Finland

Denmark

Sofia Stenius-Linna

Head of Advisense Finland

Chris Kronow Rasmussen

Director