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CASE STUDY
Strengthening Sanctions Compliance Through Expert Staff Resourcing

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Our Client
Trade has always been the foundation of our client’s business. As a Tier 1 international bank with a significant global footprint, they are a key player in global trade finance. With a network spanning multiple continents, they facilitate trade transactions across emerging and developed markets, ensuring businesses of all sizes can access international trade opportunities.
The bank employs over 5,800 trade specialists, managing complex financial transactions that support 87% of the world’s trade flows. Their systems process over US$1 million worth of trade turnover every minute, handling high-value and high-risk transactions that require robust compliance oversight.
As a financial institution with operations in multiple regulatory jurisdictions, they are subject to stringent anti-money laundering (AML), counter-terrorist financing (CTF), and sanctions regulations. Ensuring compliance with these evolving regulatory requirements is critical to maintaining their reputation and ability to operate globally.
The Challenge
Operating internationally brings inherent risks, including customer default, supplier non-performance, currency fluctuations, and diverse regulatory landscapes. Stringent AML and sanctions enforcement continue to intensify, with regulators demanding robust systems and controls.
Financial crime professionals remain in high demand, with acute shortages in financial crime monitoring, testing, risk assessment, and governance. These specialised skills are not readily available in the market.
Our client needed to review its sanctions control environment within its trade finance business across three key jurisdictions: one in the Far East, one in the Middle East, and one in Central Europe. Whilst they had a small global team, it lacked the capacity to conduct a review of the required depth and scale. Given our previous collaboration on trade finance and sanctions projects, the client turned to us for expert support.
Great things in business are never done by one person. They're done by a team of people. ~ Steve Jobs
Our Approach
Working alongside our client’s global teams, we deployed skilled resources to support:
Project Management: We provided an experienced project manager to support our client’s management team. The project manager was responsible for preparing and maintaining project plans, risk registers, and budgetary controls to ensure a structured and efficient review process. Additionally, they liaised with local management in each jurisdiction to facilitate smooth access to data, systems, and other logistical requirements. Given the complexities of working across multiple time zones, our project manager played a crucial role in monitoring overall progress and ensuring effective communication between teams. This included regular status updates and issue resolution, keeping all stakeholders aligned. Furthermore, they provided senior management with detailed reports outlining project developments and key findings, contributing valuable insights for decision-making.
Sanctions Audit Methodology Development & Implementation: A core aspect of our engagement involved developing and implementing a robust sanctions audit methodology tailored to trade finance operations. We worked closely with our client’s internal teams to establish a risk-based framework that would identify and assess potential sanctions breaches effectively. Our methodology covered key controls, transaction monitoring processes, and escalation procedures to ensure comprehensive oversight. We also provided guidance on integrating the sanctions audit methodology within our client’s existing compliance framework. This included defining key performance indicators (KPIs) and audit trails to track effectiveness, ensuring the methodology could be used for future thematic reviews and regulatory reporting.
Tailored Training Programme: To enhance the effectiveness of the review, we collaborated with our client to develop a tailored training programme. This programme covered key areas such as risk-based sanctions audit methodologies specific to trade finance operations, forensic review principles including data extraction, analysis, and reporting, and the use of technical software tools for sanctions monitoring. The training ensured that internal teams were equipped with the necessary skills to conduct effective financial crime risk assessments.
Multi-Jurisdictional Forensic Support: Given the cross-border nature of the project, we deployed in-country teams to support each jurisdiction under review. These teams were complemented by our UK-based forensic specialists, who focused on conducting forensic tests to enhance the controls review. Key forensic activities included identifying high-risk transactions and alerts, performing independent sanctions alert re-decisioning, and conducting Know Your Customer (KYC) testing. Our specialists also mapped the end-to-end transaction payment life cycles to ensure a thorough assessment of potential financial crime risks within the client’s trade finance operations.
Quality Assurance & Review Oversight: Ensuring high-quality outcomes was central to our approach. We implemented a rigorous quality assurance (QA) framework to oversee all aspects of the sanctions audit and forensic review. This involved detailed checks on fieldwork, transaction testing, and risk assessments to ensure findings were accurately documented and aligned with regulatory expectations. We also provided structured feedback to our client’s internal teams, enabling them to refine their approach to sanctions compliance. This included developing issue logs, implementing corrective actions, and ensuring that all identified risks were addressed in line with best practices.
Key Benefits & Measurable Outcomes
Our client successfully delivered a consolidated sanctions report to senior management, covering multiple jurisdictions as part of their trade finance thematic review. With our bespoke methodology and hands-on training, our client’s internal teams are now equipped to extend their reviews to additional jurisdictions.
Feedback from the local teams highlighted that the training provided broadened their skill set, enabling them to undertake wider financial crime risk assessments, including AML/CTF, bribery and corruption, and sanctions investigations.
By leveraging our expertise, our client now possesses the in-house capability to sustain and enhance their financial crime compliance framework, ensuring ongoing regulatory adherence and risk mitigation.
How We Can Help
At OpusDatum, we specialise in placing financial crime professionals in the right roles, ensuring organisations have the expertise they need to stay ahead of regulatory challenges. Contact us today to discuss how we can support your financial crime compliance needs.