Sanctions Compliance in Flux

Video

Inside the Sanctions Maze: Why Compliance Starts With Knowing Your Business

State Street’s Max Lerner on the reality of sanctions compliance in a volatile world—why success hinges on business fluency, not just expertise.

May 13, 2025

Max Lerner, Managing Director, Global Head of Sanctions Compliance & Anti-Bribery, State Street

Edwin Njenga, Head of Marketing, CeFPro

Tags: Financial Crime

The views and opinions expressed in this content are those of the thought leader as an individual and are not attributed to CeFPro or any other organization

In an era defined by geopolitical volatility, Max Lerner, Managing Director and Global Head of Sanctions Compliance at State Street Bank, emphasizes that sanctions compliance isn't just about policies—it's about partnership. The key, he argues, lies in knowing your business as deeply as you know the regulations. Without that foundational understanding, compliance becomes guesswork.

Lerner traces the evolution of sanctions from 2018 through to the sweeping 2022 Russia programs, underscoring the critical role of executive-level buy-in and surge response teams. These task forces, formed in moments of global tension, help elevate sanctions compliance from a regulatory chore to an organizational priority. But the real challenge isn’t just implementing new sanctions—it’s staying ahead of the ever-evolving evasion tactics.

Criminal networks, he notes, are well-funded and persistent, constantly recycling and refining old tactics to slip through the cracks. While no institution can catch everything, the goal is to catch enough—and to file timely suspicious activity reports (SARs) that feed into larger investigations. In this way, financial institutions act as intelligence nodes, contributing fragments of insight that regulators and law enforcement piece together into action.

On the tech front, Lerner cuts through the hype around artificial intelligence. Most current applications branded as AI are really process automation tools. The true value lies in redeploying human expertise—freeing up compliance professionals from repetitive tasks so they can focus on nuanced risk analysis and cross-border complexities.

When it comes to navigating divergent global regulatory landscapes, Lerner stresses structure: robust governance, well-defined committees, and consistent dialogue with teams around the world. But above all, success depends on compliance officers being able to speak the language of the business. Sanctions knowledge is table stakes. Translating that knowledge into real operational guidance is what sets strong programs apart.

As Lerner concludes, industry events remain crucial—not just for learning, but for networking. The value, he says, lies in peer insight and the informal knowledge-sharing that happens long after the conference ends.

Max Lerner Bio

Max Lerner is a Managing Director at State Street, a leading global bank focused in custodial, asset management and advisory, transfer agency, and administrative services based in Boston. In his role, Max is the Global Head of Sanctions Compliance and Anti-Bribery & Corruption Compliance, and as a senior member of the Financial Crime Compliance leadership team. Max is accountable for the design, management, and execution of State Street’s global sanctions and anti-bribery and corruption programs, including the screening systems and resulting alert risk analysis and resolution, policy and business unit advisory functions, regulatory engagement and investigation activities, and personnel management of teams based across the globe. Prior to his tenure at State Street, Max was Legal Regulatory Counsel at Standard Chartered Bank, a major global bank focused on retail, trade finance, commercial, and correspondent banking, based at its New York office. Max’s practice focused on AML & sanctions advisory, dispute resolution management, and regulatory engagement, investigations, and remediation. Additionally, Max currently holds the role of Chair of the Association of Global Custodians’ AML & Sanctions Committee, which brings together the top global custodian banks to address AML & sanctions issues. Max previously held a leadership role as Chapter Board Advisory Member for the Association of Certified Sanctions Specialists.

Edwin Njenga Bio

Edwin Njenga is a seasoned marketing professional with a robust background in financial services and event management. Currently serving as the Senior Marketing Manager at the Center for Financial Professionals (CeFPro)