Sanctions impact almost every aspect of our lives. They are one of few topics with real day-to-day significance, from global energy supplies (fueling our homes and cars) to global trade (products on the shelves) to travel (where we are restricted to explore) to our beloved mobile phones.
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On the macro scale, sanctions reach the top of international relations. And, in an increasingly interconnected global financial system, sanctions used by governments like the United States and United Kingdom, as well as regional bodies like the European Union, can be influential in achieving key foreign policy objectives.
Those within sanctions compliance are therefore on the front line in helping banks and financial services companies comply with complex regulatory regimes.
In recent years, fueled by large fines from regulators, sanctions compliance practitioners have become highly sought after and are riding a wave of high demand for their specialism.
But what does it take to be a successful in ensuring compliance with sanctions regimes within a firm? Having spent many years working in sanctions compliance at large global banks, here are the qualities I believe necessary.
World-class stakeholder management skills
Stakeholder management skills are required in every job but are extremely important in sanctions roles across the seniority spectrum. This is because sanctions practitioners require buy-in and should be constantly collaborating with front-office colleagues and various teams across financial crime compliance functions, all of whom can be demanding.
Inadequate stakeholder management skills will not suffice in the fast-paced world of sanctions. Positive long-term engagement with stakeholders is fundamental in influencing behavior and culture. To have an impact on culture—a focus for regulators—sanctions compliance practitioners must be close to the business. This is achieved through active collaboration with teams across the front office; it is hard to impact behaviors from behind a computer screen.
Knowledge and attention to detail
By their very nature and design, sanctions regimes can be complex and multifaceted. In some cases, where facts of a case are being applied to regulations, detailed analysis will be required, bearing in mind possible overlap (or divergence) across U.S., U.K., and EU regimes. Having a solid grasp of information and knowing the minutiae is vital to building credibility with stakeholders, some of whom will already have a good understanding of what is permissible and what is prohibited.
For example, following the collapse of the Afghan government in August, some people were surprised to learn Taliban Supreme Leader Haibatullah Akhundzada does not appear on UN, U.S., U.K., or EU sanctions lists. This leads us back to building relationships: Credibility is easily lost when the colleague you are supporting by providing specialist sanctions advice knows more than you do—or in the worst-case scenario, corrects your understanding.
Adaptability and resilience
There is a perception that resilience is required in abundance for compliance roles. This is not entirely unfounded, because there are instances where challenging conversations are necessary for meetings with stakeholders who might not fully understand individual sanctions regimes.
In such situations, sanctions compliance practitioners must adapt to audience/stakeholders; understand their business; and, where there are differences of opinion, demonstrate conviction throughout and be resilient post-meeting. Meetings with stakeholders throughout the day can vary from challenging to productive and enjoyable. It is vital to adapt quickly and enter all meetings with positivity and a readiness to contribute to the discussion.
To have a passion for sanctions, you need to believe in their underlying objective, which is generally to change the behavior of “bad actors.” While sanctions are never completely perfect, they do at least make life difficult for those who are subject to them and have had some effect in pushing individuals such as North Korea’s Kim Jong-un to the negotiating table.
Having spent many years working in the world of sanctions compliance across various banking units for large global banks, I know being interested in sanctions is a necessity for a lengthy and successful sanctions career. The subject matter is complex and practicing sanctions in the real world can be challenging, so you must enjoy it to thrive in the role.
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