2026 Top Trends: Shifting Geopolitics and Financial Crime Risks

This episode is the first in a series exploring the Top Financial Crime Compliance Trends to Watch in 2026.

Geopolitical shifts are rapidly driving sanctions and export controls and changing how countries access financial systems — creating exploitable gaps across payments, trade, shipping, and compliance operations.

This episode will help compliance and risk leaders understand:

• How sanctions evasion is evolving beyond “following the money” to “following the goods” (and the vessels moving them)
• Why trade flows, vessels, controlled/dual-use goods, and tariff evasion are increasingly central to compliance programs
• What firms can do now to stay agile as rules, risks, and enforcement priorities shift quickly 

Links:

Financial Crime Compliance Trends to Watch in 2026 infographic

Controlled Goods Screening article

Association of Certified Sanctions Specialists (ACSS) website

LexisNexis Risk Solutions website

Transcript

Saskia 0:12

Welcome back to the RegTech Pulse podcast where industry experts discuss the latest trends in financial crime compliance. It's our first episode back of 2026. I'm your host, Julia Thorn, and today we're kicking off a series on the top five trends in financial crime compliance to watch in 2026. In this episode, we're exploring the first trend from our latest infographic, and that is that shifting geopolitics are creating new vulnerabilities and financial crime risks. I'm delighted to be joined by Saskia Rietbroek, Executive Director and Co-Founder of the Association of Certified Sanction Specialists. Saskia, thank you so much for joining me today. Thank you, Julia. Happy to be here. Lovely to have you. And to start us off, Saskia, when we talk about shifting geopolitics, what does that entail and why should compliance teams be paying attention to that topic right now? Yeah, there's so much going on right now in the world. And people who work in sanctions and export controls, they're really at the uh the forefront of all these developments because they have to keep track of it and prepare their companies for these changing realities when it comes to compliance. And right now, you cannot open a newspaper or go on the internet and you hear people talking about a new world order, shifting geopolitics. So, new world order, I would rather call it a new world disorder. It's really a global, instable system right now. There's a lot of crises. And this shift away from these ordered systems towards chaos and transformation really affects people in compliance. It's not just diplomatics, people talking about foreign relations. It's driving supply chains, it's driving new sanctions, it's driving new export controls, trade restrictions. And for a compliance team, that is very impactful for their work.

The Compliance Maturity Gap

Julia 2:09

So, Saskia, we know that you know banks are the ones moving money around the world. And then one of the key places in this trend about geopolitics is how it's affecting exporters, and obviously, you know, exporters and ships and moving goods around the world. But there is this compliance maturity gap between the two. And I wonder if maybe you can dive into that a little bit from your perspective, what you're hearing at ACSS.

Shadow Fleets And Vessel Evasion

Monitoring Trade Flows Beyond Payments

Legal Gray Zones And Competitive Edge

Evasion Corridors And Geographic Risk

Practical Steps For 2026 Readiness

Resources And Closing Thanks

Saskia 2:29

Yeah, absolutely. So there's new sectors that have uh now received more rigorous compliance obligations and expectations compared to what they had in the past. And that's never easy for a sector to start working on these internal protocols to train their people. I do think it's very important that these other sectors are now being looked at by the regulators, right? The maritime shipping companies, logistics companies, import-export companies, beyond just the banks who have been regulated for a long time. Because uh sanctions evasion is like water, right? It will follow the path of least resistance. If the banks are tying everything down, then they'll try other routes. So, but for these new sectors is definitely not easy. And I often make the analogy of the seven stages of grief. So when a new regulation falls upon the roof, they'll go through these seven stages, right? First, you have uh unbelief, like why is this happening to my sector? Uh, then denial, like we don't need to do this, you know. I'm sure our bank will let us know if something is wrong. Then you have anger, right? They have fights, then ultimately, you know, start negotiating. Okay, what can we do? Depression is part of that, and then ultimately you have the uh yeah, acceptance phase that's uh they're not there yet, definitely. The banks are yeah, already in the acceptance phase, but a lot of these other sectors, their culture of compliance is really not there yet. And um, you have a lot of new people that need to take on these roles in these companies. We had a while ago somebody calling from an import-export company, and she said, until last week I was the head of accounting, and now they made me the sanctions uh and export controls compliance officer. I'm not sure what I need to do. Help me, give me some basic training. So it is definitely the there is this difference in uh levels of uh yeah, maturity. Yeah. And also, I guess you used to have, I think one thing that we spoke about before we started this recording was around scenario planning. And you can sort of plan for okay, if this happens, this is gonna happen. And you had maybe two or three scenarios which you were planning for. Those days are gone, basically, aren't they? Yeah, absolutely. You know, you could plan for a couple of scenarios. You know, if this happens, let's say if the sanctions against Syria are lifted, how can we look at our customer base? What type of transactions can we now allow? Uh, but right now you see there's so many options, you know, on the table. What can happen? New sanctions on China, sanctions uh, you know, on Iran, sanctions off Iran. And this topic has always been very dynamic. So people who work in this field, they're used to change. But the level of change that we see now, that is even difficult for people who are used to change. And that is uh yeah, that's making it harder. Some of the bigger companies they can deal with it, but if you're a smaller company and suddenly you can no longer do business with certain sectors, that is not easy to foresee and to plan for. Thanks, Askia. And another area that's coming up a lot is Shadow Fleets, you know, Russia, Iran, and others. And maybe diving into why is that making things harder in today's sectors landscape as well. Yeah. So a couple of years ago, we had to, you know, screen for names on a list. Let's say in 2023, then 2024, 2025, we have to look at corporations and who own these um these corporations. So we have to look at the entities, making sure that we follow the 50% rule. Now we have to look at vessels and shadow fleets and evasion corridors. So the focus keeps on changing. And these shadow fleet vessels, uh, sometimes called ghost fleet, they are like older anonymous cargo ships that are used to transport goods, usually oil, and they are used to bypass international sanctions, uh, safety regulations, and other laws. And in the world of global trade, most of these vessels, they're like registered cars. You know, they have clear owners, they have up-to-date insurance, they follow the rules of the road or the sea in this case. But a shadow fleet vessel is more like an old car, beat up, scratched off, uh, VIN number, fake plates, no insurance, and driving on back roads to avoid the police. So that's sort of what these vessels do. And they're used by countries under heavy international sanctions like Russia, Iran, uh, Venezuela. And they need these ships to keep on transporting their goods to the ultimate um customers. So that topic, it is very important to again not only just focus on the money streams, but also focus on the goods. And that's where these shadow fleets uh have been identified as a big risk factor. Yeah, and we've got some um some research that we did on our side where I think there was a list of 50 or so of the shadow fleet who are across all of the uh three different sanctions lists. So either on um OFEC, the EU and the UK sanctions lists. But there's many instances of them, they've got different names on those sanctions lists. You've got one instance where somebody just has kind of cut off the first and the last letters of the name, um, even just painting over that on the shy letter of a ship. So it's not, these aren't particularly always sophisticated means of sanctions evasion. You do have instances of you know AIS anomalies and chip-to-ship transfers, but some of those, the renaming side of things, it's very sort of simplistic. So it's interesting to look into and we'll we'll obviously put a little bit of content out about that one shortly as well. Um we do talk about in the FCC Transit for Graphic, which we're touching on today, we talk about in line with the Shadow Fleck piece, monitoring trade flows is just as important as monitoring money flows. So for you, you know, working in ACSS, having people approach you for advice, what is that sort of shift of monitoring not only money but monitoring trade? What does that look like, I guess, in reality for the people who are coming to you for advice? Yeah, so what we see, and actually yesterday I was at an event in uh Amsterdam of our Netherlands chapter, and this was actually a topic of discussion where we had a couple of bankers in the room, and the discussion was really about what banks are doing to make sure that their customers are not moving any restricted goods, that they have the adequate licenses if they need it. And again, the level of maturity between the banks and the customers of the banks, who are these import-export companies, is so obvious, especially when it comes to smaller companies. Also, among the banks, you have different risk levels. So some banks will still, for instance, um do business with certain countries that are under sanctions, others do not, but they are part of a payment chain, and the customers don't always realize that. So maybe your bank will say, okay, I'm gonna process, I'm gonna facilitate this payment, I'm gonna finance this trade. But maybe another bank in the payment chain, the intermediary, the correspondent bank, won't do it. And that brings another level of complexity to a transaction that goes to different countries through different banks. The fact that the banks now are to some extent expected as sort of like a regulator for their customers, right? They need to make sure that their customers are not moving goods that go to embargoed countries. And they often don't have all the information, especially when it comes to a payment. When there is trade finance, they will have more information, right? Because they know what goods they are financing. But when it's just a payment, they may have invoice number one, two, three somewhere in the fields on their platform, but they don't have any information. When they ask their customers about, okay, what are the goods that you are dealing in? Can you give me an HS code? Can we give me um a code that identifies your goods? Not all their customers are that sophisticated and they may not even know their own codes. So it is a really hard situation because the banks are seen as sort of the gatekeeper here, but ultimately their customers have exactly the same compliance obligations as the banks, and they're not always up to par in terms of what they are, what are their compliance risks. They're in business, you know, they're selling cell phones in uh, I don't know, South America, and they may not have thought about potential sanctions or export control risks. So it is that disconnect sometimes between the heavily regulated banks that push these compliance obligations, rightfully so, down to their customers. But the customers are not, you know, they're looking at their banks, okay. I'm sure you're gonna let me know when something is wrong. Yeah. And if anybody listening wants to know more about um HS codes, because that's that's a topic that we've been diving into a little bit recently as well. And I'll include in the show notes uh an article around controlled goods screening because I think that, yeah, HS codes is something that not everyone's gonna be familiar with, and and goods descriptions are not necessarily enough to be compliant in today's world. So I'll include a link to that article if anybody wants to learn a little bit more about that one. Saskia, when we talked earlier, you know, in kind of preparation for this podcast, I was asking you what's one of the biggest changes you've seen in terms of the last couple of years where things have started moving, you know, incredibly rapidly. What's one of the biggest changes you've seen? And you mentioned that people are going to their legal teams a lot more. Um how should organizations be thinking about the intersection of the compliance team and the legal team? Yeah, absolutely. I think uh up until a few years ago, a lot of uh organizations that dealt with sanctions and had to implement these sanctions, they could do it with their own internal compliance staff determining whether or not a transaction is prohibited or not. Right now, especially here in Europe, there are so many legal gray zones that it is almost impossible, I would think, to know if something is legal or not without really reaching out to your external law firm to provide you a legal interpretation. The FIQs, for instance, from the European Commission, they're super helpful, but they won't give you all the answers you need. And then there's different um, if you are a cross-border institution doing business in multiple member states in Europe, you may have different interpretations on what you can do or where you need to get the license or what license you need, if any, depending on who you ask, in what member state you will ask the question. So it's not just no longer finding names against a list. These sanctions right now, especially the sanctions against Russia, they're very complex and they go so far beyond just um name screening. And that means that you need legal expertise in order to determine if something is prohibited or not. And I think if you have good legal advice, it can also give you a competitive advantage as a business because you may be able to do business that you thought was prohibited. Yeah, and particularly, I think, like you say, it's it's knowing we can do business rather than just sort of saying, you know, we can't do that, we don't know what to do, so we're not even going to sort of try. There are areas where you can operate, you just need to know what you're dealing with. And particularly when we're seeing this fragmentation to use that word again, but yeah, there are differences between OVAC and the EU now. They're not necessarily aligned. We've seen the US temporarily easing some transactions on Russian oil, so it's very difficult to keep up. And so, yeah, I really, in terms of bringing the legal minds in because they are going to be able to kind of support in this area. Um, sort of getting towards the end of the conversation now, I think we can't ignore things like situations developing in the Middle East, everything is happening very rapidly. If you have sort of a crystal ball in terms of what do these kind of situations tell us about the future of sanctions, risk and sanctions designations. Yeah, so I think knowing about geography is becoming more and more important. What I mentioned earlier, it used to be like matching names against a list. Now you need to know about these evasion corridors. You need to be able to detect potential sanctions evasion because of the geographies that are involved or even close by the transaction that you are conducting. And I think this is quite hard. You know, for instance, if you are, let's say you're part of a transaction that goes a high technology good that is being exported from Europe to, for instance, Kyrgyzstan, could this be sanctious evasion? Could this good ultimately end up in Russia? And you would have to go beyond just an end user uh statement saying, you know, from your Kyrgyz customer saying, Well, I'm the end user and it stays here. You would actually have to know the market a little bit, you know, how many car parts or helicopter parts can be sold in Kyrgyzstan and actually be used in the local market. This is a poor country, this is a small country. So I think when it comes to sanctions evasion, which is a big topic and I think remains a big topic for the near future, you have to uh somehow being able to go beyond just red flags list, you know, have like a red flag map. I think that is something that we can expect going forward. Yeah, it's not easy, but yeah, the proximity piece, I guess, as well as rather than just location. That's yeah, who are your next door neighbors as well. Saskia, if we're wrapping up now, if you had to leave RegTech Post Podcast listeners with a few practical takeaways, what should they be doing now to prepare for the rest of 2026 and beyond? I think like one practical thing is in order to try to figure out what will be coming next, right? Because that's ultimately our, you know, compliance folks are being brought into the boardrooms and and they're being asked by the high-level board members of their corporations, okay, what can we expect? What can we see? And I think the paying attention to adverse media is helpful there because sanctions are often preceded by negative news reports. So monitor the news. Uh, if a major counterparty who is a customer is reported under investigation for potential sanctions evasion, keep that in mind. And perhaps you could somehow have a early warning sort of list of potentially sanctioned countries or entities that are coming up in the future. So that is one thing that, you know, some practical tip that I would like to give for the audience. And in general, I think training and upskilling around these new risks like shipping risks, trade risks, you need to level up your expertise across a wide range of sanctions topics beyond payments. You have to know market economics, like I mentioned before, you know, knowing these geographies, you know, what is this normal, but also yeah, know about vessel behavior, keep an eye out on trade flows, and accept ultimately that change is constant and build a program that is designed to be agile and adapt. That's brilliant. Thank you so much, Saskia. Really appreciate you joining today. Thank you, Saskia Ritbrook of ACSS. Thank you to all of our listeners for tuning in as well. If you want to download that top trends infographic, we will include a link in the show notes alongside links to both the LexisNexis Risk Solutions website and to the ACSS website. Saskia, again, thank you so much for joining me. It's been a real pleasure. Thank you. It was my pleasure, Julia. Thanks everyone for listening and stay tuned for the next episode.