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Written by Visar Jaha on Monday November 8, 2021
Sanctions impact almost every aspect of our lives, and is one of the few topics with real, day-to-day significance, from global energy supplies (fuelling our homes and cars) and global trade (products on the shelves) to travel (where we are restricted to explore) and our beloved mobile phones.
On the macro scale, sanctions reach the very top of international relations. And, in an increasingly interconnected global financial system, sanctions used by governments such as the US and the UK, as well as regional bodies like the EU, can be influential in achieving key foreign policy objectives.
Those within sanctions compliance are therefore on the frontline in helping banks and financial services companies comply with complex sanctions regimes.
Though sanctions compliance practitioners work for their employers, in practice they also help implement sanctions put in place by governments, much like internal enforcement officers. Not enforcement officers in the customary sense – more like compliance officers, who in this context would normally be involved in the process of blocking funds and making external reports to sanctions authorities.
In recent years and as a result of 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 in large global banks, here are the qualities I believe necessary.
Skilfully managing stakeholders takes up a large chunk of the day. Stakeholder management skills are required in every role 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 very 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 behaviour 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 behaviours from behind a computer screen.
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 across US, UK and EU regimes or at times divergence. 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 2021, some people were surprised to learn that the Taliban Supreme Leader, Hitbatullah Akhundzada does not appear on UN, US, UK nor 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.
There is a perception that resilience is required in abundance for compliance roles. This perception is not entirely unfounded, because there are instances where challenging conversations are necessary for meetings with stakeholders who may 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 very productive and enjoyable – it is vital to adapt quickly and enter all meetings with positivity and a readiness to contribute to discussion.
To have a passion for sanctions, you need to believe in their underlying objective, which is generally to change the behaviour of ‘bad actors’. Whilst sanctions are never completely perfect, in my view, they do at the very 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.
When I think about this final point, the quote 'If you love what you do, you'll never work a day in your life' comes to mind. Having spent many years working in the world of sanctions compliance across various banking units for large global banks, I know that 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 very challenging, so you must enjoy the subject to thrive in the role.
An interest in sanctions beyond the surface-level, and a collective and complementary set of skills, with world-class stakeholder management being one of the most important, is central to a sanctions compliance career. You can know every sanctions regime in existence, but if you do not believe in the aims of sanctions and you cannot establish working partnerships with all stakeholders, you will struggle to manage sanctions risk effectively. Above all, a successful career within sanctions compliance is underpinned by one thing more than any other – a passion for doing the right thing.
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