Sanctions Governance and Control Effectiveness Remain in Focus
This Week in Global Compliance — Sanctions Governance and Control Effectiveness Remain in Focus
February 6, 2026 — Week of 31 January–6 February
Executive Summary
The first reporting week of February continued the trajectory set in late January, with sanctions governance and control effectiveness remaining central to supervisory and enforcement narratives across major jurisdictions.
Regulatory communications and supervisory engagement in Europe and North America reiterated that sanctions risk management is being evaluated through the end-to-end effectiveness of controls, including escalation discipline, issue ownership, and senior management oversight. Authorities signaled limited tolerance for gaps between policy design and operational execution, particularly in institutions with significant cross-border payments exposure.
At the same time, supervisors reinforced expectations that institutions adapt sanctions controls dynamically as payment volumes, products, and counterparties evolve. These signals underscore that sanctions compliance is increasingly inseparable from enterprise governance and risk management frameworks.
Top Signals
1. Supervisors emphasise demonstrable sanctions control effectiveness
Regulators continued to stress that sanctions compliance assessments hinge on evidence of effective operation, not solely on the presence of policies, tools, or documented procedures.
Why it matters:
Institutions should ensure that sanctions frameworks can be evidenced through decision trails, timely escalation, and remediation outcomes aligned with identified risks.
2. Cross-border payments remain a focal point for sanctions oversight
Supervisory dialogue again highlighted payments processing and correspondent arrangements as persistent exposure points, particularly where transaction velocity and intermediary complexity challenge screening and monitoring capabilities.
Why it matters:
Banks and payments firms must validate that sanctions controls remain proportionate to transaction scale and geographic reach, with clear accountability across lines of defense.
Deep Dives
1. Regulation — Reinforcing governance expectations for sanctions frameworks
Regulatory messaging this week reinforced that sanctions compliance failures are increasingly framed as governance breakdowns, with attention on management oversight, control ownership, and timely response to identified weaknesses.
Practical impact:
- Reconfirm senior management accountability for sanctions risk
- Assess escalation thresholds and decision-making authority
- Ensure remediation actions are tracked, owned, and independently validated
2. Enforcement — Sustained scrutiny of payments-related sanctions risk
Enforcement postures continued to signal heightened scrutiny of institutions with material payments exposure, particularly where control gaps could enable prohibited transactions through indirect or intermediary channels.
Practical impact:
- Review sanctions risk assessments for payment products and corridors
- Test screening coverage across intermediary and nested relationships
- Strengthen first-line ownership and quality assurance over sanctions alerts
Data Points
- Supervisory communications continue to emphasise evidence of sanctions control effectiveness over formal policy adherence.
- Payments and correspondent activity remain among the most closely scrutinised channels for sanctions compliance.
Watchlist
- Further supervisory guidance linking sanctions outcomes to governance accountability
- Enforcement actions referencing deficiencies in sanctions escalation and remediation
- Ongoing scrutiny of payments and correspondent banking models
- Continued convergence of sanctions and broader AML governance expectations
Sources
This briefing consolidates publicly available information from global regulators, supervisory authorities, sanctions bodies, and recognised news outlets covering the week of 31 January–6 February 2026.