New EBA Guidelines To Strengthen EU-Wide Sanctions Compliance

The European Banking Authority (EBA) has published two significant sets of Guidelines on internal policies, procedures, and controls for the implementation of Union and national restrictive measures. These Guidelines, issued on 14 November 2024, represent a major step towards harmonising compliance expectations across the European Union, addressing longstanding inconsistencies in the way financial institutions manage their sanctions obligations.

The first set of Guidelines applies to all financial institutions within the EBA's supervisory remit. It establishes a framework to ensure that governance structures, internal controls, and risk management systems are sufficiently robust to address risks associated with breaches or circumvention of restrictive measures. These Guidelines emphasise the importance of conducting regular assessments of exposure to restrictive measures and tailoring compliance processes proportionately to the size, nature, and complexity of the