Skip to main content Skip to main navigation menu Skip to site footer

Automating Sanctions Compliance: Aligning Regulatory Technology, Rules and Goals

Abstract

The raft of sanctions introduced by governments throughout the world in response to the Russia-Ukraine conflict and other situations of international concern underscores the complex and rapidly changing nature of sanctions regulatory expectations. This article critically examines the extent of alignment between regulatory technology (RegTech) and sanctions compliance requirements, using the nascent Australian sanctions regime as an illustrative example. Applying insights from regulatory theory, the article differentiates between regulatory rules and goals to facilitate a nuanced evaluation of the prospects of automating sanctions compliance. It also analyses the potential disconnects between RegTech and sanctions rules arising from flaws in an automated system’s design, data inputs or underlying code, and mismatches between the capabilities of RegTech and the overarching regulatory goal of promoting a culture of compliance. The article argues that ongoing human interaction with well-calibrated RegTech tools is needed to promote alignment between RegTech and regulatory rules, and to meaningfully contribute to the broader culture of compliance goals. These insights have transferable relevance to diverse jurisdictions with complex sanctions compliance requirements and to other regulatory domains.

Published: 2023-11-21
Pages:165 to 180
Section: Articles
How to Cite
Hackney, Oliver, and Anna Huggins. 2023. “Automating Sanctions Compliance: Aligning Regulatory Technology, Rules and Goals”. Law, Technology and Humans 5 (2):165-80. https://doi.org/10.5204/lthj.2506.

Author Biographies

Australia Australia

Oliver Hackney is a manager of compliance and risk, and has worked in NGOs, not-for-profit and purpose-driven corporate organisations. Oliver has also worked as a senior research assistant at QUT Law School​ and holds a Bachelor of Laws (Hons) from QUT Law School. 

Queensland University of Technology
Australia Australia

Anna Huggins is an Associate Professor in the School of Law at the Queensland University of Technology. Anna researches and teaches in the areas of public law, regulation and compliance. Her current research explores the implications of digital, automated and data-driven regulatory processes. From 2020-2021, Anna led a research project with CSIRO's Data61 exploring the opportunities and challenges of digitising legislation. 

Open Access Journal
ISSN 2652-4074