“The ongoing challenge for private sector companies is in finding an appropriate and effective way to balance screening-oriented detection and behavioural based detection. For years, the emphasis has been in screening and indeed, as was recently seen in the UK when Office of Financial Sanctions Implementation (“OFSI”) imposed a monetary penalty on a Scottish bank, regulators are still finding companies whose name screening tools and how they are used are not up to scratch. However, the tactics observed following Russia’s illegal invasion of Ukraine has highlighted tactics involving associates, ex-spouses, friends and even strawmen (and women), shell companies and so forth – none of whom were named as designated individuals. Their identification is often the result of someone looking at both the transaction and the information provided about it, connecting the dots and saying, ”this does not make sense – let’s look more closely”.”

Samantha betonar här vikten av att kombinera traditionell screening med ett mer beteendebaserat och analytiskt arbetssätt för att upptäcka komplexa upplägg som inte fångas upp av listbaserade kontroller.
 
In the upcoming AMLR, there is an emphasis on alignment between AML/CTF and sanctions compliance. Any practical advice would you give to the OE as they prepare for these changes?
 
“ I am often surprised that I have not seen more of a reaction from fellow AML and sanction specialists around both what we have called the 6AMLD – which makes sanctions evasion and facilitation a predicate offence as of the summary of 2025 and the AMLR. Sanctions compliance is ”sprinkled” generously across several of the AML/CFT obligations throughout the AMLRs. This means that businesses completing business-wide risk assessments, reviewing TM system set up and scenarios and STR reporting procedures, forms and automated completion tech need to be assessing NOW how they are going to show that sanctions risks are being folded into the overall AML/CFT programme. Historically, we’ve not seen sanction and AML teams combining their efforts here, but these changes mean that the skills of our AML/CFT teams, and indeed the systems used for mitigation of financial crime risks, need to evolve, and quickly”. 
 
På Penningtvättsdagarna kommer Samantha att fördjupa sig i hur effektiva EUs sanktionsverktyg är, aktuella risktrender samt hur organisationer kan stärka sin motståndskraft och samtidigt förebygga sanktionsundandragande.