Sanctions risk extends far beyond sanctions screening.
Organisations are increasingly expected to understand not only direct sanctions exposure, but also indirect exposure arising through ownership structures, supply chains, customer activities, sector participation, jurisdictional presence and secondary sanctions risk.
The ComplySphere Sanctions Exposure Assessment Framework – Pro Edition provides a comprehensive methodology for assessing, managing and documenting sanctions exposure across customers, transactions and business operations.
Developed using real-world sanctions compliance principles, this framework enables organisations to implement a structured and defensible sanctions exposure assessment programme aligned to modern regulatory expectations.
What’s Included
Strategic Framework
✔ Enterprise Sanctions Exposure Assessment Methodology
✔ Regulatory Context & Definitions
✔ Direct vs Indirect Exposure Framework
✔ Risk Appetite & Threshold Setting
✔ Exposure Calculation Methodology
Assessment Tools
✔ Comprehensive Sanctions Exposure Questionnaire (SEQ)
✔ Jurisdictional Risk Assessment
✔ Business Activity Assessment
✔ Transactional Exposure Analysis
✔ Secondary Sanctions Assessment
✔ Beneficial Ownership Assessment
Governance & Escalation
✔ Tiered Risk Classification Framework
✔ Escalation Matrix & Approval Framework
✔ Senior Management Decision Framework
✔ Monitoring & Review Procedures
✔ Documentation Standards
Operational Resources
✔ Implementation Roadmap
✔ Compliance Templates
✔ Assessment Records
✔ Decision Trees
✔ Case Studies & Practical Examples
✔ Monitoring Frameworks
✔ Audit & Review Guidance
Key Benefits
- Establish a repeatable sanctions assessment process
- Assess direct and indirect sanctions exposure
- Improve governance and escalation controls
- Strengthen regulatory defensibility
- Support audits, inspections and independent reviews
- Enhance sanctions risk decision-making
Suitable For
- Banks
- Payment Institutions
- Fintechs
- Corporate Compliance Teams
- Trade Finance Functions
- Risk & Compliance Departments
- MLROs
- Heads of Sanctions
- Financial Crime Teams
© 2026 ComplySphere. All rights reserved. No part of this publication may be reproduced or distributed without written permission.




