Strengthening oversight of sanctions and adverse media risks across a complex global business
Experts reviewed sanctions and adverse media controls across a rapidly evolving financial services group, assessing how customers, connected parties, transactions and higher-risk activities were identified, screened and governed. The assessment provided senior management with a consolidated view of risk issues and a practical roadmap to strengthen controls, governance and future screening capabilities.
Brief
A diversified global financial services firm required an independent assessment of whether its sanctions and adverse media (AM) framework to identify risk issues in the design and implementation of controls across a complex and rapidly evolving business. The challenge extended beyond conventional customer screening. Senior management needed clarity on whether the right customers, related parties, transactions and higher-risk activities were consistently identified, screened and governed across legal entities, regions and specialist platforms.
The firm’s activities included correspondent and omnibus relationships, payments, securities, trade-related activity, vessels and physical delivery, digital channels and other specialist businesses. Organic growth, acquisitions, legacy systems and partially integrated processes had created different screening arrangements across the group.
The review therefore needed to distinguish isolated operational exceptions from wider weaknesses in population coverage, data flows, system configuration, decision making and governance. It also needed to provide a practical basis for immediate risk mitigation and a broader programme of sustainable enhancement capable of supporting the firm’s continued growth.
What we did
HKA conducted a comprehensive assessment of the sanctions and adverse media framework through document review, stakeholder interviews, control walkthroughs and targeted testing. The work traced how relevant parties and activities were identified, how data flowed into screening platforms, how alerts and sanctions events were managed, and how decisions, restrictions and follow-up actions were recorded and reported.
The assessment covered risk appetite and risk assessment; customer and related party screening; specialist due diligence; correspondent and omnibus relationships; acquisitions and integration; payment, securities and trade related screening; specialist asset and delivery risks; digital channels; frozen assets and licences; internal watchlists; training; management information; quality control; and assurance.
Rather than treating issues in isolation, we consolidated the evidence into a structured set of clearly bounded themes. Each issue was linked to immediate action addressing potential imminent risks, strategic remediation leading to a sustainable framework build and relevant dependencies. This enabled senior management to have a single view of how weaknesses across data, systems, processes and governance interacted.
Outcome
The assessment gave senior management a consolidated view of the key sanctions and adverse media risk issues identified across the group, helping the firm prioritise remediation and strengthen controls in the areas of greatest risk.
By grouping findings into a series of interconnected themes, the firm was able to distinguish immediate risk mitigation actions from longer term strategic remediation, supporting a more coordinated approach to control enhancement across data, systems, processes and governance.
The assessment established a credible risk and control baseline, helping the firm prioritise remediation, assign ownership and strengthen governance oversight. It also provided a foundation for future screening technology initiatives by helping ensure that underlying weaknesses in data, workflow, governance and control design are addressed before new solutions are implemented.
- Enterprise-wide assessment spanning customers, connected parties, payments, securities, trade related activity, specialist assets and digital channels.
- Multiple legal entities, regions, business models and screening platforms assessed through one integrated risk and control lens.
- Clear identification and prioritisation of sanctions and adverse media risk issues across the group.
- Immediate risk containment actions clearly separated from longer term strategic remediation.
- A consolidated roadmap linking risk assessment, population coverage, data, systems, decisions, management information and assurance.
- A stronger foundation for future screening technology initiatives, grounded in the firm’s actual risk and control requirements.
