Sanctions risk management

The brief

A large-cap technology “.com” group wanted to design and implement a globally consistent Sanctions Risk Management Framework. The group operates in the travel and tourism sector meaning that the jurisdiction-specific control design was particularly sensitive due to added reputational and regulatory pressures.

Our approach

Companies in the group are located all around the world, so defining a set of global requirements and policies required engagement with numerous internal and external stakeholders.

The core activities of this project included:

  • Engaging with technology solution providers to determine the most effective and efficient configuration of sanctions screening tools;
  • Proposing new country risk rating methodology and documenting formalised processes;
  • Facilitating discussions with external counsel in the US and EU to determine the sanctions list screening requirements;
  • Developing an industry leading approach to governance, including RACI, process and policy documentation as well as key sanctions KRI/KPI definition for the 3LOD model.

The solution and key benefits

We delivered a globally consistent approach across the Group to sanctions screening and jurisdiction specific requirements, including full blocks on sanctioned territories and other reputationally sensitive areas. The team prepared and delivered a full suite of documentation and a more effective governance model for the client.


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