Circumventing financial sanctions is a criminal offence, yet designated individuals and sanctioned entities continue to exploit weaknesses in payment systems to move or retain assets. As financial institutions act as intermediaries in global payment flows, they remain a primary target for sanctions evasion tactics that seek to bypass screening controls through data manipulation and resubmission of rejected payments.

To mitigate this risk, financial institutions must demonstrate not only effective sanctions screening technology, but also robust monitoring, testing, and governance over how rejected payments are resubmitted and processed.

Our Client

Our client is a global financial institution that had previously received a record-breaking enforcement penalty from US authorities for serious compliance failures, including sanctions breaches and money laundering control weaknesses. As part of its regulatory settlement, the institution committed to a comprehensive remediation programme to strengthen its financial crime compliance framework.

Significant investment had already been made in global AML and sanctions standards, transaction monitoring systems, and control enhancements. However, the detection of resubmitted payments with deliberately altered information remained a material residual risk requiring targeted attention.

The Challenge

Although automated sanctions screening tools were in place, they were not consistently effective at identifying resubmitted payments where key data fields—such as customer names, beneficiary details, bank identifiers, or addresses—had been removed, truncated, or subtly modified to evade detection.

This exposed the institution to continued enforcement risk, reputational damage, and potential criminal liability for senior management. Regulators increasingly expect firms to evidence not only that controls exist, but that they are subject to ongoing, independent testing and continuous monitoring.

The client therefore required a defensible, second-line framework to detect, test, and evidence the effectiveness of controls designed to prevent sanctions circumvention through resubmitted payments.

Our Approach

OpusDatum was engaged to conduct an independent assessment of the client’s resubmitted payments controls and to design a robust compliance monitoring and testing framework embedded within the second line of defence.

We began with a detailed review of existing sanctions policies, procedures, and operational controls to assess how resubmitted payments were identified, screened, and blocked. This included analysis of the sanctions compliance framework, the configuration and limitations of automated screening tools, and how payment data was captured and processed across systems.

To bridge the gap between documented policy and operational reality, we conducted structured stakeholder engagement and end-to-end process walkthroughs across global payments, compliance, and risk teams. This enabled us to identify control weaknesses, behavioural risks, and points where payment data could be manipulated during resubmission.

Building on these findings, we designed a structured compliance testing framework to enable systematic identification of altered resubmitted payments. This included risk-based sampling methodologies, repeatable test scripts, and standardised testing criteria focused on high-risk data attributes such as beneficiary names, account numbers, vessel names, intermediary banks, and jurisdictions.

We then performed independent operational effectiveness testing using real transaction data to validate whether resubmitted payments were being appropriately detected and blocked. This testing identified common circumvention techniques, including deliberate misspellings, removal of identifiers, and the use of intermediaries to obscure sanctioned links.

Finally, we designed a continuous monitoring and reporting framework, defining clear key risk indicators and management information to track trends in rejected and resubmitted payments. Escalation pathways were established to ensure timely investigation, senior management oversight, and regulatory reporting where required.

Key Benefits & Measurable Outcomes

The engagement delivered a robust and transparent framework for detecting and preventing sanctions circumvention through resubmitted payments.

Early Identification of Sanctions Risk

The monitoring framework provides an effective early warning mechanism, enabling proactive identification of emerging circumvention tactics.

Regulatory Confidence and Evidential Assurance

Structured testing and documented monitoring provide clear evidence of due diligence, supporting supervisory engagement and enforcement resilience.

Improved Control Effectiveness

Targeted testing enabled the refinement of screening parameters and operational processes, reducing the risk of altered payments bypassing controls.

Strengthened Governance and Oversight

Second-line ownership of monitoring and reporting improved accountability and senior management visibility of sanctions risk.

Enhanced Reputational Protection

By demonstrating a proactive and intelligence-led approach to sanctions compliance, the institution strengthened trust with regulators and stakeholders.

Is Your Organisation Equipped to Prevent Sanctions Circumvention?

Sanctions evasion tactics continue to evolve, particularly through manipulation of payment data and resubmission processes. Financial institutions must be able to evidence not only effective controls, but ongoing assurance.

If your organisation needs to strengthen its sanctions compliance framework or implement independent monitoring over resubmitted payments, OpusDatum can help.

Contact us today to discuss how we can support robust, regulator-ready sanctions compliance.