John Gibson, Dan Burbeary and Alice Mills unpack a critical shift in sanctions compliance in their recent FT Adviser article, “Sanctions checks no longer confined to screening exercises.” Drawing on two July 2025 English Commercial Court decisions, they explain why ticking names off a sanctions list is no longer enough, and how courts, banks and counterparties are now demanding deeper, evidence-based assessments of ownership, control and influence. As market pressure, US secondary sanctions and judicial scrutiny converge, sanctions diligence has moved decisively from screening to investigation, with substance trumping form and process often determining outcomes. A must-read for businesses, compliance teams and advisers navigating today’s sanctions risk landscape.
