What it takes to work in sanctions compliance – Part 2

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Written by Visar Jaha on Monday 10 January, 2022

The first article showed part of the skills that a sanctions professional needs to have in their toolkit. This second piece will look at other complementary skills and how readers can obtain and cultivate them.

World-class stakeholder management skills, attention to detail, adaptability, resilience and a passion for sanctions – all are vital attributes for those working in sanctions compliance. 

But these form only part of a sanctions professional’s toolkit. For a long and successful career in sanctions compliance, they will also need to demonstrate further complementary skills: communication, teamwork, organisation and emotional intelligence. Here, I’ll discuss how these skills can be obtained and cultivated.

Communication

Email is not the be all and end all. For communication with colleagues to be effective, a range of communication styles must be applied, whether in person (in a meeting room or by a desk), through email, on the phone, and, more often these days, virtually, such as through Microsoft Teams and Zoom. There are distinct differences between these forms of communication and in my experience, the message delivery should vary depending on the context. For example, the following short statement, ‘we can’t support this business because of possible sanctions implications’, contained in an email, provides little context or detail for a client-facing relationship team who would ultimately need to deliver that message to a client.

What it takes to work in sanctions compliance – Part 2

Good practice would include clear detailed communication so that the client-facing relationship teams can understand the rationale behind any guidance. This may well encompass an offer of a follow-up meeting to discuss any points that need clarifying. The underlying tone in communications, whether in person or on the phone or online, must always be appropriate and measured, beginning at the top (a wider focus for regulators). Perception of messages is also key, especially in fast-paced dynamic environments. Asking yourself ‘how does this sound?’, ‘how might it be received?’ and ‘can it be improved?’ is therefore particularly important.

Teamwork

Sanctions professionals of course need to work closely within their own teams. But teamwork must also extend outwards to other departments if sanctions teams are to operate as partners and trusted advisors to the business. Though sanctions compliance teams must retain independence and impartiality, the starting point for collaboration should be a one-team outlook. Bridging the gap between sanctions teams and front-office teams yields great results internally in the pursuit of managing sanctions risk and ultimately has a positive effect on overall client relationships.

What it takes to work in sanctions compliance – Part 2

Most organisations have some level of complexity, especially large banks with various teams supporting clients. This could include relationship teams, client management services, onboarding teams, product teams, compliance teams, legal teams and payments teams, etc. Understanding different teams across an organisation, including their roles, responsibilities and priorities, is vital for sanctions compliance professionals. For example, where there is a need for specific information on a client around transactions activity – and specific details on SWIFT information – the payments team may be better placed to help, compared to, for instance, the relationship team, who may not have access to SWIFT systems. To ensure long-term success, sanctions professionals need to actively collaborate with all teams, and even more so with the front office. Where teams work together seamlessly, sanctions risk can be managed far more effectively.

Organisation

The skill of being able to effectively triage requests for sanctions advice into a sanctions team is fundamental. Organising urgent requests for guidance requires the ability to apply sanctions regimes to facts and conduct a risk assessment to identify any possible sanctions risk – something especially important in sanctions compliance as the clock is ticking as soon as risk is identified.

What it takes to work in sanctions compliance – Part 2

Sanctions professionals will also be involved in providing guidance, to customers using everyday banking products such as current accounts and mortgages to trade finance facilities. Real-world and real-time events for clients can have an impact on the work of sanctions teams. For example, sanctions teams may be engaged on urgent escalations for mortgage customers or trade finance transactions for which avoidable time delays can have an adverse impact on the ground. Sanctions teams need to be client-centric and prioritise such escalations where necessary to assist clients; this feeds into the wider purpose of ultimately supporting clients. A constant awareness and understanding is required by sanctions professionals of that which needs immediate attention, and they must organise their workload accordingly. This should be balanced with managing expectations in a fast-paced environment, which can be challenging when there are competing priorities. 

Emotional intelligence

The role of a sanctions compliance professional requires high levels of emotional intelligence, during the good times and even more so in times of crisis. Learning to recognise signs of emerging complexity in a scenario and knowing when approaches need to be adapted is hugely important. This leads me back to teamwork, which can only move forward where sanctions professionals listen attentively, encouraging collaboration, and creating through what they say (positive reinforcement) and what they do (actions) an environment where all teams feel that they can engage.

What it takes to work in sanctions compliance – Part 2

There will be instances where sanctions compliance professionals find themselves at the forefront of managing sanctions risk, mitigating the risk by taking the lead and coordinating various actions. It is crucial to be able to recognise how potential events can make people feel and be always ready to take a step back and see the bigger picture. For example, sanctions compliance professionals play a significant role in assessing possible regulatory and policy breaches, events which by their nature can be stressful and evoke various emotions.

The future of sanctions

Whilst the global pandemic has had a slowing effect on the entire world economy, sanctions developments have not slowed down. Serious developments that emerged in 2021 included, for instance, Belarus, Afghanistan and Myanmar, as well as problems connected to the ongoing COVID-19 crisis. A large cache of skills – stakeholder management, knowledge, attention to detail, adaptability, resilience, communication, teamwork, organisation, emotional intelligence – are today more important than ever for sanctions professionals in what is a dynamic and forever-changing sanctions landscape.


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