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AML/CFT AML Training BSA Rules and Regulation Financial Crime OFAC SAR

Balancing sanctions compliance and operational efficiency: How to adapt for sustainable compliance

Terri Luttrell, CAMS-Audit, CFCS
March 2, 2026
0 min read
A panel of experts from top regulatory supervisory agencies compiled 10 AML hot topics to look out for in 2022

Balancing sanctions compliance and operational efficiency

Financial institutions face mounting pressure to maintain effective sanctions compliance while dealing with staffing limitations, growing watchlists, and increasing alert volumes. As regulators raise expectations and list-based screening becomes more complex, institutions may struggle to be both thorough and efficient.

The goal is sustainable sanctions compliance. That means building a risk-based program that prioritizes compliance efficiency without compromising effectiveness. When institutions focus only on volume, more sanctions screening, more alerts, more reviews, they often create burnout and inconsistent results. Instead, a targeted approach to alert management, staffing, and technology can improve both speed and quality in sanctions processes.

Capacity management for sanctions staff

The Office of Foreign Assets Control (OFAC) continues to expand and update sanctions programs. These updates are critical for national security, but they also increase alert volumes for compliance teams already working with limited resources.

As backlogs grow, staff may spend valuable time clearing low-risk matches rather than investigating real threats. This not only reduces morale but also affects the institution’s overall alert management effectiveness.

Instead of defaulting to more rules or over-screening, institutions should evaluate whether their current programs support both risk mitigation and compliance efficiency. A sanctions staffing assessment can help identify pain points and opportunities to reallocate or optimize resources.

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The OFAC 50% rule

A risk-based approach becomes even more critical when applying complex guidance, such as the OFAC 50% rule. This rule extends sanctions compliance beyond individuals or entities named on the Specially Designated Nationals (SDN) list. Any company that is 50 percent or more owned, directly or indirectly, by one or more sanctioned parties is also considered a blocked entity, even if it does not appear on any official list.

In a recent enforcement action, private equity firm IPI Partners was penalized for indirect dealings with Russian oligarch Suleiman Kerimov, who was on the SDN list. Though Kerimov did not directly own 50 percent of the involved entity, OFAC determined that his control and benefit were sufficient to trigger enforcement under the 50% rule.

This case underscores why sanctions compliance cannot rely solely on list matching. Institutions must have systems and trained staff in place to analyze ownership structures, document decisions, and escalate concerns when red flags appear.

The role of beneficial ownership and CDD

Robust customer due diligence (CDD) processes are the backbone of effective sanctions compliance. Institutions should collect beneficial ownership information during onboarding and update it regularly as part of ongoing due diligence. High-risk customers or businesses with layered ownership structures require enhanced scrutiny. Without this information, institutions cannot meet OFAC’s expectations around the 50% rule.

Gathering ownership data is not enough. Institutions must have the tools and processes to analyze and aggregate indirect ownership stakes. The burden is on the financial institution to identify and act on ownership risk, even in the absence of a public 50% list. A well-maintained CDD program also supports more accurate risk rating and enables targeted alert management that aligns with the institution’s risk profile.

Regulatory expectations

Examiners are paying close attention to how institutions apply the 50% rule and manage screening results. Documentation is key. Institutions must clearly record how they determined ownership percentages, what screening results were escalated, and why certain matches were cleared. Policies and procedures should define who is responsible for reviews and when ownership concerns should trigger further investigation.

OFAC does not expect perfection, but it does expect accountability. Institutions should be able to explain their approach and support it with data and documentation.

Consistency over complexity

A sustainable program prioritizes consistency in decision-making and risk management. Overly complex screening rules can lead to inefficiencies, missed alerts, or inconsistent escalation practices. Institutions should ensure their sanctions compliance processes include:

  • Standardized screening logic across systems
  • Risk-based alert thresholds and triage protocols
  • Regular tuning and validation of alert scenarios
  • Data-backed decisions to avoid unnecessary false positives

This kind of structure supports more effective alert management and allows institutions to reallocate staff time toward higher-risk reviews rather than clearing low-priority alerts.

Risk-based screening

Regulators support a risk-based approach to anti-money laundering and sanctions compliance, and the guidance outlines expectations of a sanctions risk assessment. Applying this strategy to screening means financial institutions can:

  • Prioritize enhanced screening where risk justifies it
  • Reduce unnecessary alerts by adjusting thresholds
  • Focus human review on high-impact cases
  • Create a documented framework for oversight and governance

This improves both compliance efficiency and audit readiness by demonstrating that the institution understands and controls its risk exposure.

Technology supporting compliance

Technology is essential in scaling sanctions compliance programs without adding headcount. Tools like Abrigo’s anti-money laundering and fraud detection solutions can automate screening, improve triage, and support case management.

Systems that incorporate ownership analysis, list updates, and scoring can streamline alert management while enhancing accuracy. OFAC screening software technology should support human decision-making, not replace it. When properly configured, it becomes a multiplier for staff effectiveness.

Building a program that evolves

Compliance demands are changing rapidly. Institutions must create flexible programs that grow with their sanctions risk profiles. That means:

  • Keeping ownership documentation up to date
  • Training staff on emerging guidance and escalation procedures
  • Proactively applying enforcement trends like the OFAC 50% rule
  • Aligning tools and staffing with current and future alert volumes

Sustainable sanctions compliance is not about chasing every alert. It is about building a program that adapts, scales, and withstands scrutiny without overwhelming your teams.

 

Sanctions compliance requires people

No technology can replace the judgment of a well-trained professional. Sanctions compliance requires dedicated personnel who can evaluate ownership risk, interpret evolving guidance, and escalate when something does not feel right. Institutions facing turnover or resource gaps should consider conducting a staffing assessment to ensure they can continue to meet expectations without coverage gaps.

Compliance is evolving, but it does not have to be overwhelming. With the right combination of people, process, and technology, your institution can build a resilient, risk-based program that balances thoroughness with efficiency.

What is sanctions compliance and why does it matter for financial institutions?
What does “sustainable sanctions compliance” mean?
Why is a risk-based approach critical in sanctions programs?
What is the OFAC 50% rule and how does it affect screening?
How can institutions improve alert management in sanctions screening?

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About the Author

Terri Luttrell, CAMS-Audit, CFCS

Compliance and Engagement Director
Terri Luttrell is a seasoned AML professional and former director and AML/OFAC officer with over 20 years in the banking industry, working both in medium and large community and commercial banks ranging from $2 billion to $330 billion in asset size.

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About Abrigo

Abrigo enables U.S. financial institutions to support their communities through technology that fights financial crime, grows loans and deposits, and optimizes risk. Abrigo's platform centralizes the institution's data, creates a digital user experience, ensures compliance, and delivers efficiency for scale and profitable growth.

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