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First Look: Early Insights from the 2026 Sanctions Screening Trends Survey

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149 responses and counting. Here’s what compliance teams are signaling as we head into 2026.   With geopolitical volatility, expanding sanctions regimes, and a regulatory shift toward program effectiveness, compliance teams are reassessing the foundations of their screening programs. Early results from our 2026 Sanctions, Watchlist & PEP Screening Trends Survey highlight five themes shaping the coming year.   This “first look” focuses on the questions that most clearly illustrate how prepared institutions feel, where they are struggling, and how they expect to evolve.  

AI/ML Adoption: Modernization Moves From Optional to Expected

AI adoption is accelerating quickly.  
  • Already using AI/ML: 41.22%
  • Planning adoption within 12 months: 38.51%
  • Planning adoption later: 11.49%
  More than 80% of respondents are either already using or actively preparing to adopt AI/ML for reducing false positives, improving match quality, triaging alerts, and enhancing explainability.   AI is no longer viewed as experimental or “nice to have.” The technology is emerging as an operational necessity, driven by mounting alert volumes, partner-level oversight requirements, and increasing documentation expectations. Institutions recognize that manual processes alone cannot meet 2026 regulator expectations, especially as effectiveness testing and back-testing become more visible parts of examinations.  

Confidence in Meeting 2026 Expectations: Cautious Optimism, But Not Comfort

Question: How confident are you that your program can meet evolving screening expectations?  
  • Very confident: 37.16%
  • Somewhat confident: 39.19%
  • Neutral: 17.57%
  • Not very confident: 4.73%
  • Not confident: 1.35%
  Roughly three-quarters of respondents feel at least somewhat confident—but only one in three report being “very confident.” The data suggests that institutions believe they can meet expectations. However,  many are still solidifying how they will demonstrate effectiveness to regulators. Much of the uncertainty likely stems from interpretive challenges, especially around model governance, documentation, cross-regime alignment, and ongoing monitoring.  

Jurisdictional Alignment: A Persistent and Growing Operational Strain

Question: How challenging is cross-regime compliance?  
  • Very challenging: 31.76%
  • Somewhat challenging: 52.03%
  • Not challenging: 13.51%
  This overwhelming majority reflects real pressure. Sanctions regimes are diverging more than they are converging, and institutions increasingly operate across markets, partnerships, or customer bases that trigger multi-regime exposure. This complexity also feeds downstream issues:  
  • More discrepancies between lists
  • More evasion typologies
  • More need for explainability
  • More pressure on data sourcing and governance
  These challenges directly tie into what regulators are asking for: clear rationale, governance records, and defensible program decisions, not just matching technology.  

Biggest Challenges Today: Data Quality and Ownership Complexity Dominate

  Respondents were asked to choose their single biggest challenge:  
  • Data quality: 26.85%
  • Beneficial ownership complexity: 16.11%
  • Cross-regime compliance: 14.77%
  • False positives: 11.41%
  • Investigations backlog: 11.41%
  • Lack of skilled resources: 11.41%
  • Crypto exposure: 7.38%
  Data quality stands out as the leading barrier to effectiveness. As sanctions lists expand, corporate ownership structures become more layered, and adverse media sources multiply, teams are struggling to maintain consistency and completeness.   Beneficial ownership complexity and cross-regime challenges closely follow. This reinforces how critical integrated, high-quality data is to program performance.   Furthermore, false positives, backlogs, and resource shortages show that operational capacity remains tightly linked to screening quality, a gap AI and automation aim to close.  

Priority Outcomes for 2026: Faster Decisions and Stronger Governance

When asked which outcomes matter most for improvement (select up to three), respondents reported:  
  • Faster alert triage/investigation: 52.35%
  • Enhanced model governance/explainability: 46.98%
  • Better documentation/auditability: 42.28%
  • Back-testing / effectiveness statements: 30.87%
  • False positive reduction: 29.53%
  Effectiveness expectations are reshaping how institutions invest and operate. The emphasis on triage speed, explainability, and documentation quality, shows that regulators’ expectations are moving deeper into the “how” and “why” of screening decisions.   Institutions are signaling that 2026 will focus less on the volume of alerts and more on the quality of decisions, the strength of supporting evidence, and the consistency of governance practices.   The fact that false positive reduction remains a top priority but is no longer the only priority, could also indicate a market shifting from reactive noise reduction to proactive risk-based oversight.

Looking Ahead

  These early findings point to a sanctions screening environment that is rapidly evolving:  
  • AI adoption is accelerating.
  • Cross-regime complexity is growing.
  • Data quality remains foundational.
  • Regulators expect deeper documentation, governance, and back-testing.
  • Most teams feel cautiously confident—but not yet fully comfortable.
  Alessa will publish the full 2026 Screening Trends Report at the beginning of next year. The final report will offer deeper insights to help institutions benchmark themselves and prepare for what’s coming.   Interested in sharing your insights on how sanctions, watchlist and PEP screening will evolve in 2026? Take our short survey today and be entered into our weekly draw for a chance to win a $50 Amazon gift card.

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