New poll of legal, compliance and financial services professionals also finds almost six in ten organisations have not recently tested whether their sanctions escalation process would work under pressure
Nine in ten compliance, legal and financial services professionals (90%) lack full confidence that their organisation would spot a sanctioned individual hiding behind a shell company or a complex ownership structure, according to a new poll of 146 professionals by compliance training and software provider, VinciWorks.
Fewer than one in ten (9.6%) respondents described themselves as very confident. Close to half (46%) were only fairly confident, three in ten (30%) were only somewhat confident, and about one in seven (15%) said they were not very confident or not confident at all.
The findings revealed that six in ten (60%) could not say their organisation’s process for escalating a potential sanctions match had been tested recently. Only two-fifths (40%) described their process as both clear and regularly tested, and seven per cent admitted their approach depended on one or two particular individuals rather than a documented procedure.
The same poll also found that compliance teams are more exposed on judgement-based checks than on basic screening. More than half (55%) named establishing ownership and control or understanding end users and supply chains as their greatest challenge. Only around one in ten (11%) pointed to screening names and counterparties, suggesting the industry’s difficulty lies less in checking a sanctions list and more in seeing through the structures behind it.
Training also remains inconsistent. Almost three in five (58%) highlighted sanctions training as part of an ongoing programme. The remaining two in five (42%) had either trained staff once as a standalone session, not yet introduced training, had no plans to do so, or did not know whether staff had been trained at all.
Naomi Grossman, compliance manager at VinciWorks, said, “90% of compliance professionals telling us they lack full confidence in this area should concern any organisation operating across borders. Sanctions regimes have grown far broader than a simple list of frozen bank accounts. An organisation that only checks whether a customer’s name appears on a list is missing the transactions that create the greatest exposure. We have to be conscious of possible transactions where a legitimate-looking buyer is owned or controlled by someone who is designated, or where goods pass through several jurisdictions before reaching a sanctioned end user.”
The findings come as regulators intensify enforcement action worldwide. In June 2026, the UK’s Office of Financial Sanctions Implementation (OFSI) issued its largest ever penalty for a financial sanctions breach since Russia’s 2022 invasion of Ukraine, fining travel technology firm Sabre Global Technologies over £1m for continuing to provide services to a Russian airline after its designation, including an attempt to route a payment through an account outside the UK. In the USA, cryptocurrency exchange Binance pleaded guilty in 2023 to violating anti-money laundering and sanctions laws and agreed to pay more than $4.3bn in penalties, with its then chief executive also pleading guilty and resigning. Both cases involved exactly the kind of indirect exposure that goes beyond simply checking a name against a sanctions list.
“It’s also striking that almost six in ten of the organisations asked have not tested their sanctions escalation process recently,” Grossman added. “A policy on paper does not show whether, in the moment a sanctions match appears, the right people know what to do. Sanctions compliance is often a race against the clock to make sure a breach doesn’t happen. Sanctions screening and escalation systems need to be tested regularly, if not, the regulator will be the one examining why they failed.”
As sanctions regimes grow more complex and enforcement more assertive, many compliance teams are still working out what a genuinely tested programme looks like in practice. VinciWorks has written more on this in Sanctions Enforcement in Action: Recent Cases, Enforcement Trends and Practical Lessons, which looks at what recent penalties reveal about regulators’ expectations. Also, explore VinciWorks’ sanctions training built around these kinds of real-world scenarios, for teams who want to test how their own people would respond.
New poll of legal, compliance and financial services professionals also finds almost six in ten organisations have not recently tested whether their sanctions escalation process would work under pressure
Nine in ten compliance, legal and financial services professionals (90%) lack full confidence that their organisation would spot a sanctioned individual hiding behind a shell company or a complex ownership structure, according to a new poll of 146 professionals by compliance training and software provider, VinciWorks.
Fewer than one in ten (9.6%) respondents described themselves as very confident. Close to half (46%) were only fairly confident, three in ten (30%) were only somewhat confident, and about one in seven (15%) said they were not very confident or not confident at all.
The findings revealed that six in ten (60%) could not say their organisation’s process for escalating a potential sanctions match had been tested recently. Only two-fifths (40%) described their process as both clear and regularly tested, and seven per cent admitted their approach depended on one or two particular individuals rather than a documented procedure.
The same poll also found that compliance teams are more exposed on judgement-based checks than on basic screening. More than half (55%) named establishing ownership and control or understanding end users and supply chains as their greatest challenge. Only around one in ten (11%) pointed to screening names and counterparties, suggesting the industry’s difficulty lies less in checking a sanctions list and more in seeing through the structures behind it.
Training also remains inconsistent. Almost three in five (58%) highlighted sanctions training as part of an ongoing programme. The remaining two in five (42%) had either trained staff once as a standalone session, not yet introduced training, had no plans to do so, or did not know whether staff had been trained at all.
Naomi Grossman, compliance manager at VinciWorks, said, “90% of compliance professionals telling us they lack full confidence in this area should concern any organisation operating across borders. Sanctions regimes have grown far broader than a simple list of frozen bank accounts. An organisation that only checks whether a customer’s name appears on a list is missing the transactions that create the greatest exposure. We have to be conscious of possible transactions where a legitimate-looking buyer is owned or controlled by someone who is designated, or where goods pass through several jurisdictions before reaching a sanctioned end user.”
The findings come as regulators intensify enforcement action worldwide. In June 2026, the UK’s Office of Financial Sanctions Implementation (OFSI) issued its largest ever penalty for a financial sanctions breach since Russia’s 2022 invasion of Ukraine, fining travel technology firm Sabre Global Technologies over £1m for continuing to provide services to a Russian airline after its designation, including an attempt to route a payment through an account outside the UK. In the USA, cryptocurrency exchange Binance pleaded guilty in 2023 to violating anti-money laundering and sanctions laws and agreed to pay more than $4.3bn in penalties, with its then chief executive also pleading guilty and resigning. Both cases involved exactly the kind of indirect exposure that goes beyond simply checking a name against a sanctions list.
“It’s also striking that almost six in ten of the organisations asked have not tested their sanctions escalation process recently,” Grossman added. “A policy on paper does not show whether, in the moment a sanctions match appears, the right people know what to do. Sanctions compliance is often a race against the clock to make sure a breach doesn’t happen. Sanctions screening and escalation systems need to be tested regularly, if not, the regulator will be the one examining why they failed.”
As sanctions regimes grow more complex and enforcement more assertive, many compliance teams are still working out what a genuinely tested programme looks like in practice. VinciWorks has written more on this in Sanctions Enforcement in Action: Recent Cases, Enforcement Trends and Practical Lessons, which looks at what recent penalties reveal about regulators’ expectations. Also, explore VinciWorks’ sanctions training built around these kinds of real-world scenarios, for teams who want to test how their own people would respond.
