Sanctions Compliance Officer

The role differs by size of firm. In a large bank it may be a head of sanctions with a team of analysts. In a small business it may be one person with several duties. The officer writes and updates the sanctions policy, oversees the risk assessment, and decides how screening is set up. Staff bring difficult alerts and unusual deals to the officer, who judges whether to proceed, block, report or apply for a licence. The officer also trains colleagues, watches changes to sanctions law, deals with regulators and reports on breaches and trends to senior management and the board. Supervisors expect the person to have enough seniority, resources and independence to say no. In some firms the role is combined with the money laundering reporting officer. When something goes wrong, supervisors look first for someone with real authority who was in charge.

A trade finance desk at a mid-sized bank is asked to confirm a letter of credit for goods going to a port that sanctions authorities have flagged for diversion. The relationship manager escalates the case. The sanctions compliance officer asks for end-user evidence, declines when none arrives, records the reasoning and tells the head of trade finance about the changed risk.