This Week in Global Compliance — Sanctions Enforcement and Payments Oversight Intensify

January 30, 2026 — Week of 24–30 January

Executive Summary

The final reporting week of January was marked by heightened sanctions enforcement signals and supervisory focus on payments and correspondent exposure, reinforcing regulators’ emphasis on control effectiveness over formal compliance design.

Authorities in Europe and North America advanced actions and guidance clarifying expectations for sanctions screening, escalation, and governance, particularly where institutions process high volumes of cross-border payments or rely on complex intermediary structures. Supervisors continued to link sanctions breaches and control gaps to broader governance and risk management failures.

At the same time, regulators reiterated expectations that payments firms and fast-scaling financial institutions maintain sanctions and AML controls proportionate to their operational footprint, underscoring that growth and innovation do not dilute compliance accountability.

Top Signals

1. Sanctions enforcement increasingly tied to governance accountability

Supervisory statements and enforcement outcomes this week reinforced that sanctions compliance failures are being assessed through a governance lens, including senior management oversight, issue escalation, and remediation ownership.

Why it matters:
Institutions should expect sanctions incidents to trigger broader reviews of governance frameworks, not only control tuning or list management processes.

2. Payments and correspondent activity remain a supervisory priority

Regulators reiterated that high-velocity payment flows and correspondent relationships continue to present elevated sanctions and AML risk, particularly where monitoring relies on legacy assumptions or incomplete counterparty data.

Why it matters:
Payments firms and banks must ensure sanctions screening and transaction monitoring models reflect current typologies and transaction complexity across jurisdictions.

Deep Dives

1. Regulation — Clarified expectations for sanctions control effectiveness

Regulatory guidance issued this week emphasized demonstrable end-to-end sanctions control effectiveness, including alert handling, escalation decisioning, and timely remediation of identified weaknesses.

Practical impact:

Review sanctions governance frameworks and escalation thresholds
Validate alert investigation quality and documentation standards
Ensure remediation tracking is visible at senior management and board level

2. Enforcement — Supervisory pressure on payments governance

Enforcement activity and supervisory engagement continued to focus on payments providers and institutions with significant cross-border exposure, highlighting deficiencies in sanctions screening coverage and control ownership.