Ropes & Gray’s FCA sanctions review analysis highlights improved compliance but rising supervisory expectations for demonstrable controls and closer FCA coordination with OFSI and OTSI

It also finds that significant weaknesses persist—especially in customer due diligence, ongoing monitoring, trade finance controls, and the consistency of sanctions screening outcomes across jurisdictions and business lines. The article emphasises that the FCA is now shifting toward a more proactive, risk-based supervisory model, where firms are expected not only to have policies in place but to demonstrate that controls are effective…