Navigating the Convergence of Sanctions & AML Regimes
Insights from the Experts
📅 March 11, 2025
📅 March 11, 2025
In a recent webinar, leading professionals in sanctions and financial crime risk management convened to discuss the convergence of sanctions and anti-money laundering regimes. The panelists offered insights into how these two sectors have been merging and provided practical advice for professionals to navigate this complex landscape.
Among the distinguished speakers were:
The event was moderated by Danny McGlynn, the President and Chief Integrity Officer of IFI.
The webinar aimed to demonstrate the convergence of sanctions and anti-money laundering regimes and the importance of breaking departmental silos in jurisdictions and financial institutions and the necessity for a comprehensive, holistic approach to compliance and risk management associated with sanctions and financial crimes.
Danny McGlynn began with an overview of the evolution of the convergence of sanctions and financial crimes compliance over the years, which underscored the need for institutions to adapt to the changing landscape. He highlighted how the convergence has been multifaceted and can be broken down into four main areas: targeting of common conduct, reliance on common preconditions, evolution of common compliance program pillars, and emergence of common red flags.
With respect to the targeting of common conduct, McGlynn highlighted how over the past 25 years six criminal activities that are considered money laundering predicate offenses targeted by AML/CFT regimes—terrorism, WMD proliferation, corruption, human rights violations, organized crime, and narcotics trafficking—have increasingly also become conduct targeted by sanctions regimes imposed by the U.S., EU, UK, and UN.
The panelists agreed on the deep link between sanctions and AML/CFT regimes and the importance of breaking down the silos between sanctions and AML/CFT departments in both the public and private sector. This was the key takeaway from the lesson of 9/11. From a threat, vulnerability, and control perspective, convergence of sanctions and AML/CFT is necessary if we’re going to be effective in combating financial crime, advancing collective security, and protecting the integrity of the financial system.
The panelists offered the following specific insights and best practices on breaking down silos:
Panelists discussed the common preconditions for effective sanctions and AML/CFT measures, pointing out that protecting the international financial system from criminal abuse by identifying and closing systemic vulnerabilities through heightened transparency measures and accountability has long been an overarching objective of the global AML framework.
At the same time, effective implementation of sanctions policy also requires a transparent and accountable international financial system to enable the identification of sanctioned activities and interests of sanctioned individuals and entities. Achieving such financial transparency and accountability requires effective jurisdictional and institutional implementation of preventive measures—backed by sound supervision and enforcement—as called for by AML/CFT regimes.
With respect to institutional implementation, the panelists cited guidance published by OFAC in 2019—A Framework for OFAC Compliance Commitments—and highlighted that the essential elements of a sanctions compliance program are very similar to the AML program requirements: management commitment, risk assessment, customer due diligence / know your customer (CDD/KYC), internal controls, testing and auditing, and training.
Turning to common red flags that banks and others should be on the lookout for regarding money laundering and sanctions evasion activities, the panel discussed several advisories and alerts that OFAC and FinCEN have issued over the past few years. These alerts have provided examples of red flags that can signal when and how third parties and intermediaries may be engaged in efforts to evade sanctions or export controls. Many of these red flags are the same or similar to longstanding AML-related red flags, demonstrating that AML controls and investigations can be helpful in detecting sanctions evasion and uncovering assets and transactions of designated parties.
On Iran, for example, FinCEN last year issued an advisory focused on sanctioned Iran-backed terrorist organizations like Hamas and Hizballah. The advisory includes case studies and typologies on how they raise and move funds, as well as specific red flags like:
OFAC has also issued a series of advisories focused on shipping that have included red flags such as:
The panel noted that many of the red flags included in these advisories and alerts have been informed by the government’s engagement with the private sector and emphasized the importance of continued cross-sector information-sharing and public-private partnerships.
The panelists emphasized that the biggest problem faced by financial institutions is less about the identification of red flags and the theories behind them and more about having the systems to put them into practice in a repeatable manner. The ability to operationalize red flags in a way to effectively identify and mitigate risk is very difficult, especially at very large financial institutions. The governance and implementation framework is as important or more important than the actual red flags, and regulators reviewing AML and sanctions programs are going to look for consistency of implementation across the enterprise.
The panelists offered the following specific insights and best practices on how to detect potential sanctions and trade control evasion:
Join the Institute for Financial Integrity Wednesday March 5th for a webinar on the convergence of sanctions and financial crimes compliance featuring a panel of experts.
Key topics to be addressed include:
This site uses cookies. By continuing to browse the site, you are agreeing to our use of cookies.
Accept settingsHide notification onlySettingsWe may request cookies to be set on your device. We use cookies to let us know when you visit our websites, how you interact with us, to enrich your user experience, and to customize your relationship with our website.
Click on the different category headings to find out more. You can also change some of your preferences. Note that blocking some types of cookies may impact your experience on our websites and the services we are able to offer.
These cookies are strictly necessary to provide you with services available through our website and to use some of its features.
Because these cookies are strictly necessary to deliver the website, refusing them will have impact how our site functions. You always can block or delete cookies by changing your browser settings and force blocking all cookies on this website. But this will always prompt you to accept/refuse cookies when revisiting our site.
We fully respect if you want to refuse cookies but to avoid asking you again and again kindly allow us to store a cookie for that. You are free to opt out any time or opt in for other cookies to get a better experience. If you refuse cookies we will remove all set cookies in our domain.
We provide you with a list of stored cookies on your computer in our domain so you can check what we stored. Due to security reasons we are not able to show or modify cookies from other domains. You can check these in your browser security settings.
These cookies collect information that is used either in aggregate form to help us understand how our website is being used or how effective our marketing campaigns are, or to help us customize our website and application for you in order to enhance your experience.
If you do not want that we track your visit to our site you can disable tracking in your browser here:
We also use different external services like Google Webfonts, Google Maps, and external Video providers. Since these providers may collect personal data like your IP address we allow you to block them here. Please be aware that this might heavily reduce the functionality and appearance of our site. Changes will take effect once you reload the page.
Google Webfont Settings:
Google Map Settings:
Google reCaptcha Settings:
Vimeo and Youtube video embeds:
You can read about our cookies and privacy settings in detail on our Privacy Policy Page.
Privacy Policy