Sanctions lists are a basic requirement for accurate and reliable sanctions monitoring, but they’re just the starting point. On paper, they offer a way to identify sanctioned entities. In practice, sanctions risk is driven by how effectively managers and compliance teams can turn data and updates into action.
Sanctions monitoring has no single authoritative list. Compliance teams are required to track dozens of sources, maintained by different agencies and regulators, updated on different schedules, and published in different formats. Changes can occur at any time, including multiple times a day.
As governments increasingly rely on sanctions as a policy tool, firms face mounting pressure not only to keep lists up to date, but to implement changes before a breach occurs.
Sanctions are imposed in real time, often in response to rapidly evolving geopolitical developments. Internally, however, firms rely on systems and processes that are far slower. Even when the data is technically available, delays in detection, review, and application create sanctions exposure.
Risk accumulates in the gaps between steps. Updates are flagged late or missed entirely. Alerts are generated but not actioned. Changes are applied in one workflow but overlooked in another. It’s when execution drags that stale data goes from potentially impactful to harmful. As regulators increase expectations, firms are judged not only on whether they had access to the right data, but whether they acted on it in a timely manner.
A key challenge lies in how sanctions lists are published. Some regulatory bodies, like the Office of Foreign Assets Control (OFAC) in the United States, release changes quickly in structured, machine-readable formats. Others, like the European Union, publish updates that require extensive manual cleanup and custom setup before they can be used and integrated with internal systems. Names may appear with limited context, late in the week, embedded in documents unsuitable for automation.
Even once interpreted, many organisations struggle to apply updates consistently. Manual processes don’t scale. They introduce inconsistency, slow down response times, and make it difficult to demonstrate control. The more fragmented the workflow and the slower the execution, the longer the window of risk remains open.
This is where a sanctions monitoring platform becomes a control layer. Data, no matter how accurate, has limited value if it sits outside an automated system capable of detecting changes, triggering reviews, and applying decision logic consistently.
An effective platform turns sanctions updates into action. It continuously monitors for changes, flags them quickly, and incorporates them into existing workflows. The relevant stakeholders are prompted to review, decisions are recorded, and updates applied across ongoing monitoring and trading. The ideal outcome is one that reflects both an awareness that something has changed, as well as clear, auditable execution. Data can and should act as a catalyst, but can only do so with the right infrastructure supporting it.
High quality sanctions data remains integral to sanctions monitoring. Without it, no system or platform can function effectively. But data alone doesn’t close the gap between regulatory change and internal response. Automation does.
It’s the combination of reliable, accurate sanctions data and intelligent automation that makes monitoring at scale possible. By removing execution latency, eliminating manual bottlenecks, and applying changes consistently across compliance and investment processes, firms can reduce exposure and demonstrate control.
The partnership between FundApps and BIGTXN reflects this model in practice in the Sanctions Monitoring service, pairing continuously updated data feeds with automation that turns change into action. Client holdings are monitored against ten different sanctions regimes, with potential breaches flagged directly on the service platform. For each alert, clients are provided with details on the issuer in question, the domains it’s sanctioned in, and the reason for the sanction. With all the information front and center, teams are equipped to respond with speed, consistency, and confidence.