Sanctions Compliance for Non-Dedicated Roles: 5 Top Tips

In smaller or mid-sized companies, wearing multiple hats is often the norm. For many professionals, this means juggling responsibilities across legal, compliance, and operational functions. If you’re the designated “responsible person” for sanctions compliance but also have a full workload as, say, an in-house lawyer, accountant, or operations lead, balancing these obligations can feel overwhelming.

Sanctions compliance is a serious business—failure to adhere can result in significant fines, reputational damage, and even criminal penalties. But don’t worry; you don’t need a dedicated compliance team to do this right. With the right approach, you can effectively manage sanctions compliance alongside your other responsibilities.

Here are five top tips to help you stay on top of sanctions compliance, even when it’s just one of the many plates you’re spinning.

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1. Get Clear on Your Sanctions Obligations

Why it matters: Sanctions lists and regulations vary across jurisdictions and are updated frequently. Knowing what’s required of your business is critical to avoid unintentional violations.

• Understand the relevant regimes: Identify the sanctions lists applicable to your operations, such as the UK Sanctions List (managed by the Office of Financial Sanctions Implementation, OFSI), the US OFAC list, or the EU sanctions framework. Your company’s geographic footprint, supply chain, and customer base will determine which lists are relevant.
• Know your company’s risk areas: If your business involves international trade, high-risk industries (e.g., finance or technology), or dealings with politically sensitive regions, your exposure to sanctions risks may be higher.
• Focus on high-risk transactions: Prioritise compliance efforts on areas most susceptible to sanctions violations, such as payments, supply chain partners, or new client onboarding.

Quick action: Bookmark OFSI’s website and subscribe to updates for new sanctions announcements. Similarly, consider monitoring other jurisdictions if you operate internationally.

2. Leverage Technology to Streamline Screening

Why it matters: Managing sanctions compliance manually while juggling other roles is inefficient and error-prone. Automating parts of the process can save time and reduce risk.

• Use sanctions screening tools: Invest in a user-friendly, cost-effective tool like sanctions.io, which can automatically screen customers, vendors, and transactions against updated sanctions lists. These tools simplify due diligence and flag potential matches in real time.
• Integrate with existing systems: If possible, integrate sanctions screening into your CRM, ERP, or payment platforms to ensure seamless checks at every relevant stage.
• Set alerts for ongoing monitoring: Some tools provide continuous monitoring, notifying you if an existing client or partner is added to a sanctions list after onboarding.

Quick action: Explore free or low-cost solutions if budget constraints are an issue. Even smaller-scale businesses can find tools that are affordable and easy to implement.

3. Implement a Simple, Scalable Compliance Framework

Why it matters: Without clear processes, you risk missing steps or applying inconsistent standards, which could lead to violations. A straightforward compliance framework can guide you through routine checks without overcomplicating things.

• Write it down: Document a simple process for sanctions checks. For example:some text
  1. Screen all new customers, vendors, and partners against the UK Sanctions List.
  2. Perform enhanced due diligence (EDD) for any flagged matches.
  3. Report any confirmed sanctions hits to OFSI immediately.
• Make it scalable: Your framework should be easy to follow but robust enough to handle growth. For instance, consider implementing thresholds for escalating risks, such as involving external experts when EDD is required.
• Train your team: Even if you’re the primary person responsible, ensure other key staff understand the basics of sanctions compliance to share the load when needed.

Quick action: Develop a one-page checklist for sanctions compliance tasks and keep it visible in your workspace.

4. Keep Records and Document Everything

Why it matters: If an audit or investigation occurs, having a clear paper trail can demonstrate your company’s compliance efforts. Failing to document checks could result in fines, even if no actual violation occurred.

• Maintain logs of checks: Whether it’s a customer screening, a supplier review, or a transaction flagged for potential risk, keep detailed records of your findings and actions.
• Use a central repository: Store compliance records in a single, organised system that is accessible but secure. This can be as simple as a shared folder or as advanced as a compliance software platform.
• Retain records long enough: OFSI recommends retaining records for at least six years. Ensure you comply with this timeframe and consider the same for other jurisdictions you operate in.

Quick action: Create a dedicated “Sanctions Compliance” folder in your company’s shared drive and organise it by year and transaction.

5. Don’t Be Afraid to Ask for Help

Why it matters: You’re juggling multiple responsibilities, and sanctions compliance can get complicated quickly. Asking for help when needed can save time, reduce stress, and ensure better outcomes.

• Engage external experts: If you encounter complex scenarios (e.g., screening a high-risk client or navigating multi-jurisdictional sanctions), consult with a compliance specialist or external legal counsel.
• Talk to your regulators: OFSI and similar bodies in other jurisdictions often provide guidance to companies. Reach out if you’re unsure about an issue; they’d rather help you avoid violations than penalise you after the fact.
• Share the load internally: If possible, delegate routine tasks (e.g., screening new customers) to a junior team member or another department with proper training.

Quick action: Build relationships with compliance consultants or law firms that specialise in sanctions. Having someone on speed dial can save precious time during a crisis.

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Why Sanctions Compliance Matters

Even if it’s not your full-time job, sanctions compliance must be taken seriously. The consequences of a breach can range from hefty fines to reputational damage, or worse, being barred from operating in certain markets. For smaller and mid-sized companies, where resources are often stretched thin, a single violation could be catastrophic.

Final Thoughts: Sanctions Compliance For Non-Dedicated Roles

As the responsible person for sanctions compliance in your organisation, you have a challenging but critical role. The key to balancing this with your other responsibilities is simplification and prioritisation. By leveraging technology, creating scalable processes, and knowing when to ask for help, you can protect your company from sanctions risks without sacrificing your sanity.

Remember, sanctions compliance isn’t just a box-ticking exercise—it’s about safeguarding your business’s future in an increasingly complex global marketplace. With these five tips, you’ll be better equipped to handle this important responsibility, no matter how full your plate is.

sanctions.io is a highly reliable and cost-effective solution for AML and sanctions screening. AI-powered technology, an enterprise-grade API boasting 99.99% uptime, and an easy-to-use portal, it’s no surprise that customers worldwide trust sanctions.io to enhance their compliance processes.

Book a free Discovery Call now. We also encourage you to take advantage of our free 7-day trial (no credit card is required).