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In the full episode, we break down the European Banking Authority’s newly issued guidelines designed to standardise how financial institutions across the EU implement restrictive measures and sanctions controls. The rules apply broadly to banks, payment service providers, and crypto-asset firms, aiming to eliminate inconsistencies in how sanctions are enforced across member states.
At the heart of the framework is a mandatory restrictive measures exposure assessment, requiring firms to evaluate how their specific business models, customers, and geographies expose them to sanctions risk. This assessment is meant to directly inform risk management strategies, screening systems, and internal controls.
The guidelines also introduce clear accountability requirements, including the appointment of a senior staff member responsible for sanctions compliance with direct reporting lines to the management body. We explore additional operational expectations such as screening calibration, staff training, escalation processes, and obligations around asset freezing and potential sanctions matches.
Overall, the episode explains how these EBA standards represent a major step toward intelligence-led, harmonised enforcement across the EU—and why firms that fail to adapt risk falling behind in an increasingly stringent regulatory environment.