Trade finance plays a critical role in facilitating global commerce, but it also presents heightened exposure to money laundering, bribery, fraud, and sanctions evasion. Criminal actors exploit the complexity of trade transactions by manipulating invoices, misrepresenting goods, or disguising counterparties to move illicit funds through the financial system. Regulators, including the Financial Conduct Authority and the Wolfsberg Group, have repeatedly highlighted weaknesses in trade finance controls and called for stronger sanctions screening and governance.

OpusDatum was engaged to provide independent assurance over trade finance sanctions screening controls for a financial institution operating at significant transaction scale.

Our Client

Our client operates a sophisticated trade finance function supporting corporate and institutional clients engaged in cross-border trade. The business provides a range of services, including supply chain finance, structured trade finance, and export credit facilities, enabling clients to manage liquidity and mitigate commercial risk.

With an average monthly processing volume of approximately 40,000 trade transactions, the institution operates in a high-risk environment where effective sanctions compliance is critical. The trade finance function is supported by automated transaction monitoring, KYC due diligence, and real-time sanctions screening to mitigate financial crime exposure.

The Challenge

Trade finance transactions involve multiple counterparties, evolving documentation, and complex cross-border flows, often spanning jurisdictions with differing sanctions regimes. This complexity increases the risk of inadvertent sanctions breaches and exposes institutions to significant regulatory and reputational consequences.

The client had implemented a global, system-based sanctions screening solution integrated into its core trade finance platform. However, given the dynamic nature of trade transactions—where counterparties, vessels, goods, and transaction details can change over time—the institution required independent validation that its sanctions screening controls were operating effectively in practice and aligned with global sanctions policies.

The challenge was to assess not only the design of the sanctions framework, but its operational effectiveness, consistency of alert handling, and alignment with regulatory expectations.

Our Approach

OpusDatum applied its specialist financial crime audit methodology to conduct an independent assessment of sanctions controls within the client’s UK trade finance operations.

We began with a detailed review of the global sanctions policy and associated trade finance procedures, assessing alignment with current regulatory requirements and evaluating how consistently policy expectations were embedded into operational practice.

A forensic analysis of the sanctions screening process was then undertaken, focusing on transaction identification, alert generation, investigation quality, and escalation. This included comparison of historic alert decisions with independent reassessment to identify inconsistencies, control weaknesses, or potential blind spots within the screening framework.

Using our specialist alert review methodology and proprietary review tools, we independently assessed sanctions alerts generated by the system. Alerts were classified as false positives, true matches, or requiring further investigation, with clear rationale documented for each outcome. This enabled targeted refinement of screening parameters and improved alert quality.

We also assessed procedural adherence by reviewing how analysts followed escalation protocols, sought additional information, and documented decision-making. Patterns in alert handling were analysed to evaluate consistency across teams and alignment with regulatory expectations.

Key Benefits & Measurable Outcomes

The engagement delivered clear, actionable assurance over the effectiveness of the client’s trade finance sanctions controls.

Strengthened Sanctions Compliance

Independent validation confirmed alignment between policy, systems, and operational practice, reducing the risk of sanctions breaches.

Improved Senior Management Oversight

Clear insight into sanctions screening performance enabled more informed governance and risk-based decision-making.

Enhanced Alert Management Efficiency

Forensic analysis supported refinement of screening parameters, reducing unnecessary alerts while improving detection of genuine risk.

Improved Consistency and Control Discipline

Identification of procedural inconsistencies informed targeted training and control enhancements, strengthening compliance culture.

Reduced Regulatory and Reputational Risk

Independent assurance provided confidence that trade finance operations were resilient to sanctions evasion tactics and aligned with supervisory expectations.

Strengthen Your Trade Finance Sanctions Controls

Sanctions risk in trade finance continues to evolve as criminals exploit complexity and documentation gaps. Financial institutions must be able to demonstrate that sanctions controls are not only in place, but operating effectively.

If your organisation requires an independent assessment of trade finance sanctions screening or broader financial crime controls, OpusDatum can help.

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