Hiring a Sanctions Lead: What the Role Needs Since 2022
Before 2022, sanctions compliance at many UK regulated firms was one task among many for the MLRO: screen customers against the list, check payments, report any matches. The scale and speed of the sanctions imposed on Russia changed that. Designations ran into the thousands, ownership and control tests became central, and the UK moved to a strict liability approach to civil penalties. For firms with international customers or payment flows, sanctions became a specialism in its own right. This guide covers when a firm needs a dedicated sanctions lead, what the role involves, and what to look for when hiring one.
Why Sanctions Became a Specialism
Several changes since 2022 have made sanctions compliance harder and the cost of getting it wrong higher:
- Volume and pace. The number of UK designations rose dramatically, with frequent updates. Screening lists, rules and processes have to keep up.
- Ownership and control. Firms must identify entities owned or controlled by designated persons, even when the entity itself isn’t listed. That requires investigation, not just screening.
- Strict liability. The Economic Crime (Transparency and Enforcement) Act 2022 removed the need for OFSI to prove a firm knew or suspected a breach before imposing a civil monetary penalty.
- Wider measures. Restrictions on services, trade, securities and specific sectors mean sanctions risk now goes well beyond checking names against a list.
- Circumvention. Attempts to evade sanctions through third countries, complex structures and front companies have grown, and supervisors expect firms to look for them.
- Multiple regimes. Firms with international business must often consider UK, US and EU sanctions together, and they don’t always align.
The FCA has also made clear that it expects firms to have effective systems and controls to counter the risk of being used to breach sanctions, and it has reviewed sanctions controls across the industry. Our guide to sanctions screening and financial sanctions compliance covers the obligations in detail.
What a Sanctions Lead Does
| Area | Typical responsibilities |
|---|---|
| Risk assessment | Assessing the firm’s sanctions exposure by customer, product, geography and payment flow |
| Screening | Owning customer and payment screening, list management, rule tuning and false positive reduction |
| Alert handling | Overseeing alert review and escalation, and deciding difficult potential matches |
| Ownership and control | Investigating whether customers or counterparties are owned or controlled by designated persons |
| Reporting and licensing | Reporting frozen assets and suspected breaches to OFSI, and handling licence applications |
| Change | Implementing new designations and measures quickly, and briefing the business |
| Policy and training | Maintaining the sanctions policy and training staff on red flags and circumvention |
| Reporting to the MLRO and board | Providing management information on screening performance, matches, breaches and emerging risk |
The sanctions lead usually reports to the MLRO or head of financial crime. Sanctions isn’t a separate Senior Manager Function, so accountability at Senior Manager level normally sits with the MLRO or another Senior Manager whose Statement of Responsibilities covers it.
When You Need a Dedicated Sanctions Lead
Not every firm needs one. A small, UK-focused advice firm with domestic clients can usually manage sanctions within the MLRO’s role, supported by a good screening tool. The case for a dedicated lead grows with:
- international customers, especially from or connected to higher-risk jurisdictions
- cross-border payments, trade finance or correspondent relationships
- complex corporate customers where ownership and control is hard to establish
- high screening volumes and persistent false positive backlogs
- exposure to multiple sanctions regimes
- previous breaches, near misses or supervisory findings on sanctions
- growth into new markets or products with sanctions exposure
Payments and e-money firms, private banks and wealth managers with international clients, trade finance businesses, cryptoasset firms and wholesale brokers are the most common hirers. Our guide to sizing the financial crime team at a payments or e-money firm shows where a sanctions specialist fits in a growing team.
What to Look For
The best sanctions candidates combine technical knowledge with investigative skill and calm judgement under time pressure. Look for:
- Hands-on screening experience. They should understand how screening tools work, how to tune them and how to reduce false positives without creating gaps.
- Ownership and control investigations. Ask for examples of complex structures they have unpicked, and how they reached and recorded a conclusion.
- Regulatory contact. Experience of reporting to OFSI, handling licence applications, or responding to supervisory reviews.
- Multi-regime knowledge. Where your firm has US or EU exposure, familiarity with OFAC and EU measures alongside UK sanctions.
- Sector relevance. Payments sanctions work differs from private wealth or trade finance. Match the candidate’s background to your business.
- Clear communication. The sanctions lead often has to tell the business, quickly, that a transaction can’t proceed. They need the confidence and clarity to do it.
Interview Questions That Work
- Walk us through a potential match you escalated. What did you check, and what did you decide?
- Tell us about an ownership and control case that wasn’t straightforward. How did you reach a view?
- How did you reduce false positives in your last role, and how did you know you hadn’t created a gap?
- How did your firm respond to a major new package of designations? What was your role?
- Describe a time you had to stop a transaction the business wanted to proceed with.
- What circumvention red flags would you expect to see in our business?
Strong candidates give specific, structured answers with clear decisions. Our guide to MLRO interview questions covers judgement-based questioning for financial crime roles more broadly.
Scenario: A wealth manager with a growing client base in the Gulf and Central Asia relies on its MLRO to handle sanctions alongside everything else. Its screening tool generates hundreds of alerts a week, most of them false positives, and reviews are falling behind. An internal review finds two clients whose corporate structures include entities with links to designated persons that the screening didn’t catch. The firm appoints a dedicated sanctions lead with private wealth experience, who retunes the screening rules, introduces a structured ownership and control review for complex clients, and reports monthly to the MLRO and the risk committee.
Pay and Market
Experienced sanctions specialists have been in high demand since 2022, and the pool of people with genuine ownership and control experience is small. Pay typically sits in line with financial crime manager roles, which our salary guide puts at around £65,000 to £110,000 in London, with senior sanctions heads at larger firms earning more. Interim sanctions specialists are also common, particularly for firms dealing with a backlog, a remediation programme or a sudden change in exposure. Our page on interim MLRO and compliance recruitment covers short-term financial crime cover.
Where the Sanctions Lead Fits
A sanctions lead is usually one of the specialist roles added beneath the MLRO as the financial crime function grows, alongside a deputy MLRO, transaction monitoring and investigations leads. Our guides to deputy MLROs and the head of financial crime and MLRO roles explain how the pieces fit together. Our financial crime leadership recruitment practice recruits sanctions leads alongside the other senior financial crime roles.
Financial Crime Leadership Recruitment
Specialists for the risks that matter. Every SMF search is led personally by Adrian Lawrence FCA
Financial Crime Team
Sanctions, investigations and more.
→ Financial crime leadership → Deputy MLROsHead of financial crime or MLRO? →
Guidance
The rules behind the roles.
→ Sanctions screening → PEPs explainedThe MLRs explained →
Sectors
Where sanctions risk is highest.
→ Payments and fintech → Wealth managementCryptoasset firms →
Every SMF search is led personally by Adrian Lawrence FCA
Frequently Asked Questions
Is sanctions part of the MLRO’s role?
At most firms, yes: sanctions usually sits within the financial crime remit the MLRO oversees. A sanctions lead supports the MLRO rather than replacing that accountability.
Does a sanctions lead need FCA approval?
No. It isn’t a Senior Manager Function, although the firm must be satisfied the person is fit and proper for the role.
Can sanctions screening be outsourced?
Screening tools and alert handling can be outsourced, but the firm remains responsible for compliance, and someone senior inside the firm needs to own the decisions.
How long does it take to hire a sanctions lead?
Typically two to four months, depending on seniority and notice periods. Interim specialists can usually start within weeks.
About the Author
Adrian Lawrence FCA is the founder of SMF Capital. He is a Chartered Accountant and Fellow of the ICAEW, holds a practising certificate in his own name, and is a former listed-company Finance Director with a BSc from Queen Mary College, University of London. He founded FD Capital in 2018 and has since built a network of five specialist recruitment practices. He leads every SMF Capital search personally. View Adrian’s ICAEW profile.
Need a Sanctions Specialist?
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Adrian Lawrence FCA is the founder of SMF Capital and a Fellow of the Institute of Chartered Accountants in England and Wales and holds an ICAEW practising certificate in his own name. He holds a BSc from Queen Mary College, University of London, and has over 25 years of experience working with boards, investors and business owners across the UK. He founded SMF Capital to help FCA and PRA-regulated firms appoint the Senior Managers the regulators expect, with the fit and proper assessment built into every search, and personally leads every Senior Manager Function search.