Testing the Knowledge of Sanctions Professionals

Sanctions activity is intense, fragmented and fast moving. New designations, list retirements, thematic programmes and enforcement developments happen regularly and often simultaneously across major regulators.

To see how sanctions professionals are keeping up, at the beginning of 2026 we hosted a quiz with the Association of Certified Sanctions Specialists (ACSS) to test their knowledge (and add a sense of fun!). Around 200 people (both ACSS members and non-members) joined the 20-question quiz, hosted by me and Howard Spieler, ACSS New York City Chapter Lead, which covered enforcement, policy changes and technical rules.

The results were revealing, and highlighted where collective understanding is strongest, and where uncertainty persists.

Where confidence was highest

Some areas showed strong consensus and high accuracy. Ownership and control rules were particularly well understood. Seventy-eight percent of participants correctly identified the status of an entity owned 51% by an SDN under US rules, even where control was not exercised. This suggests that core compliance mechanics, especially those with direct operational consequences, are firmly embedded.

Similarly, the audience performed well when quizzed on enforcement driven developments. Almost 80% correctly identified which agency removed the most Syria-related designations during the easing of sanctions in 2025.

Another strong area was thematic enforcement. Seventy-eight percent correctly linked fraud-related sanctions targeting largescale scams to cyber sanctions programmes, reflecting growing familiarity with how sanctions are used beyond traditional geopolitical contexts (or familiarity with our H1 2025 Sanctions Pulse eBook which we encouraged participants to read ahead of the quiz).

Where the knowledge gaps lie

The most striking insight was where participants didn’t get it right.

Only 16% correctly identified which UN sanctions programme triggered the most new asset freezes in 2025. Could it be that the UN is less top of mind for sanctions professionals who have spent recent years grappling with Russian-based sanctions from OFAC, the EU, UK and other major bodies?

Another notable gap related to FATF alignment. Only 35% correctly identified which UN targeted financial sanctions are incorporated into FATF Recommendations. This is an important finding, as FATF expectations increasingly influence supervisory scrutiny and risk assessments.

The most divisive questions

Some questions resulted in widely distributed answers. These included questions pertaining to the largest set of designations in 2025 (an OFAC action targeting Russia in January), which month in 2025 saw the largest number of designations were added (October), and which program is unique to OFAC (narcotics trafficking). 

In each case, responses were spread relatively evenly across all possible answers. This points less to misunderstanding, and more to the sheer complexity and fragmentation of the sanctions landscape. When multiple regulators act in parallel, often with overlapping narratives, it becomes genuinely hard to retain a single “correct” interpretation without structured tracking. 

What this tells us about sanctions in 2026

Three broader conclusions stand out from the results.

1. Sanctions knowledge is strongest where rules are operationalized daily (ownership thresholds, enforcement actions) and weakest where obligations are indirect or multilateral (UN programs, FATF alignment).
2. Pace of change outstrips collective recall. Even highly engaged professionals struggle to keep an accurate count of packages, additions and list changes over a single year.
3. Structural and technical developments (such as list retirements or rule suspensions) are harder to track than headline designations, despite their long term compliance impact.

None of this reflects a lack of education or professionalism; rather a sanctions environment that has become more dense, fast, and multi-layered.

It also raises an important question for organizations in 2026: how can you ensure your teams are keeping up with rapid change? Because in a world of continuous sanctions change, what we think we know can diverge quickly from what regulators expect us to know.

Test your knowledge!