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Making the EU Sanctions Helpdesk even more practical for SME MLROs

It involves a spreadsheet

Author

Paul Huston
March 26, 2025

Just want the spreadsheet? - get the google sheet here and make a copy.

The EU just launched a Sanctions Helpdesk for SMEs in March 2025.

It’s a big step forward.

But… it could be even more practical for FinCrime pros.

I’ve pulled together a few tweaks/suggestions:
1. Categorised Red Flags for easy scanning
2. Clarifying Questions to cut confusion
3. Yes/No Checklists to speed up decision-making

The goal? Make MLROs’ lives simpler so they can spot issues fast and stay compliant. Check out my slides and let me know which parts resonate—or what could be improved.

I would love to hear what else you’d recommend/whether you disagree with my approach.

1. Group Red Flags by Category (I created 23)

Image of categories I created to help MLROs use EU Sanction Helpdesk

  • Why It Matters: Instead of dealing with random red flags, cluster them (e.g., Transaction Structure, Country Risk, Documentation)

  • Benefit: This approach helps you zero in on the exact risk area—no guesswork needed

  • Outcome: Quicker decisions on where to focus deeper due diligence

2. Ask the Right Clarifying Questions

  • Clear Guidance: For each red flag, a straightforward question shows what to verify (e.g., “Is there an unexplained shell company?”)

  • Empower Your Team: Anyone scanning a deal can flag suspicious details using these simple prompts

  • Reduce Errors: Direct, scenario-based questions cut down on confusion and missed signals

3. Use Yes/No Checkboxes for Quick Calls

  • Instant Visual: Checking a box for each red flag offers an immediate risk snapshot.

  • Consistent Documentation: A record of answers helps you build a strong audit trail

  • Easy Collaboration: Multiple teams can share and update the same checklist with minimal friction

Go forth and check! 

EU Sanctions Helpdesk: It’s a great resource for SMEs but you need to leverage their red flags, don’t let them just be words on a page

You’ll still need to do your own checks but they can assist: Make sure you’re thinking through the right q’s and possibilities

Stay Ahead: By quickly pinpointing red flags you’ll protect your program from costly Sanctions pitfalls