Sanctions & export controls
Evaluating the interplay between sanctions on financial institutions and systemic risks in the international banking sector.
A rigorous examination of how sanctions targeting banks ripple through financial systems, potentially amplifying contagion, complicating liquidity management, and reshaping risk governance across cross-border networks.
Published by
Richard Hill
August 02, 2025 - 3 min Read
Financial sanctions are a central instrument of international diplomacy, yet their effects extend beyond political signaling. When authorities cut access to global payment rails or restrict correspondent banking, sanctioned institutions face abrupt liquidity squeezes and counterparties reassess risk profiles. This recalibration can provoke funding gaps, alter pricing in cross-border lending, and push risk toward less regulated corridors. At the same time, non-targeted banks with exposure to sanctioned clients may experience indirect pressure through counterparty defaults, asset repricing, and tighter margin conditions. The systemic dimension emerges when multiple institutions in different jurisdictions confront simultaneous stress, testing the resilience of payment systems, clearinghouses, and liquidity facilities designed for stable operation.
The design of sanctions packages matters for systemic stability. Narrow, targeted measures aim to minimize spillovers, yet even well-calibrated actions create discontinuities in funding chains. Banks that rely on correspondent relationships with sanctioned counterparts may face sudden denials of service, forcing them to seek alternative routes at higher cost. Financial institutions must rapidly assess counterparty risk, adjust risk-weighted assets, and reprice credit products to reflect new liquidity horizons. Regulators, in turn, confront the difficulty of maintaining market confidence while safeguarding legitimate transactions. The balance between punitive aims and financial stability requires ongoing coordination among policymakers, central banks, and supervisory authorities across jurisdictions.
Contagion channels and regulatory coordination in crisis scenarios.
A core concern is how sanctions influence liquidity risk across the network of international banks. When correspondent banking lines are disrupted, payment flows can fragment, delaying settlement and increasing funding costs. Banks may hedge against this by diversifying counterparties, building domestic clearing capacity, or utilizing alternative currencies, all of which can alter competitive dynamics. Yet these shifts introduce new operational risks, including complex settlement timeliness, reconciliation errors, and cybersecurity vulnerabilities as systems span multiple jurisdictions. The net effect often depends on the speed of policy implementation, the transparency of exemptions, and the degree to which smaller banks can access essential services without exposing themselves to sanction-related penalties.
The reputational dimension compounds structural risk. Institutions connected, even indirectly, to sanctioned entities may face precautionary withdrawals from customers and investors who fear inadvertent violations. This reputational spillover magnifies credit spreads and funding costs, particularly for banks with limited balance-sheet diversification. Compliance-intensive environments may hamper innovation and the introduction of efficient cross-border payment technologies. Regulators therefore must ensure that compliance guidance is clear and that sanctioned environments do not destabilize legitimate lenders serving ordinary clients. Clear communication about permissible activities, robust screening protocols, and credible enforcement can reduce uncertainty without weakening sanctions’ strategic aims.
Ethical considerations and the public interest in capital markets.
Contagion channels in this space operate through liquidity contagion, credit channel effects, and market sentiment. If a major bank reduces cross-border activity due to sanctions exposure, its counterparties may shrink risk exposures across the entire network, triggering a chain reaction. Central banks can mitigate this by providing targeted liquidity facilities, offering temporary exemptions for routine commerce, and coordinating with international bodies to preserve essential payments. Yet such interventions must be carefully calibrated to avoid moral hazard or providing undue support to sanctioned institutions. The overarching objective is to maintain continuity in core services while preserving the integrity of sanctions as foreign policy tools.
Systemic risk hinges on data quality and transparency. Financial authorities rely on timely, comparable information about exposure, funding gaps, and capital adequacy to gauge systemic vulnerabilities. When disclosures lag or are incomplete, institutions might misprice risk, leading to abrupt repricing or sudden liquidity withdrawals. Strengthening data-sharing agreements between supervisors, stress-testing frameworks, and cross-border incident response plans can help. This requires harmonized reporting standards, mutual recognition of supervisory actions, and clear channels for crisis communication. The aim is to detect early signals of strain and coordinate responses that minimize the likelihood of a disorderly withdrawal of funding.
Risk governance and resilience-building in financial institutions.
Ethical considerations arise when sanctions intersect with the public interest in financial stability. Policymakers must weigh the punitive purpose of sanctions against potential harms to ordinary savers and businesses that depend on stable access to global markets. Shielding vulnerable communities from unintended consequences becomes part of the calculation, especially in economies with shallow banking systems or high dependence on international payments. Mechanisms such as targeted exemptions, humanitarian carve-outs, and time-bound restrictions can help, provided they are transparent and enforceable. If accountability is lacking, legitimate actors may lose confidence in the system, undermining both sanction objectives and market integrity.
The complexity of cross-border enforcement underscores the need for robust governance. Banks operate in a mosaic of legal regimes, and inconsistent enforcement can create arbitrage opportunities that undermine policy aims. Coordinated action among sanctioning authorities, financial intelligence units, and supervisors enhances predictability. At the same time, proportionality matters; sanctions should be adjusted to evolving risk assessments and international law standards. A governance framework that emphasizes regular review, peer learning, and joint crisis exercises can strengthen resilience without stifling legitimate trade and investment activities.
The path forward for policymakers and markets.
For banks, resilience means more than capital adequacy; it encompasses operational resilience, cyber readiness, and robust third-party risk management. Sanctions-driven constraints can expose vulnerabilities in vendor networks, payment rails, and information-sharing platforms. Institutions that invest in diversified payment corridors, redundant IT systems, and scenario-based planning often fare better during periods of stress. Regulators increasingly expect boards to oversee these resilience measures, requiring disciplined incident response, clear escalation pathways, and documented recovery plans. A culture of proactive risk management helps institutions withstand external shocks without collapsing into liquidity crises.
Financial institutions can build resilience by refining liquidity risk frameworks. Stress testing should incorporate sanctions-related scarcities, potential sanctions backlogs, and counterparty diversification strategies. Early warning indicators, such as widening funding spreads, unusual settlement delays, or rising reliance on a limited set of counterparties, can prompt preemptive actions. Firms that maintain transparent communications with clients, counterparties, and regulators during stress events tend to preserve trust and avoid destabilizing rumors. The end goal is to maintain service continuity while remaining compliant with evolving sanctions regimes.
Looking ahead, the interaction between sanctions and systemic risk will demand continuous tuning and robust information flows. Policymakers should pursue precision in targeting, paired with flexible adjustment mechanisms that reflect changing geopolitical realities. Markets benefit from clarity on permissible activities, timelines for sanctions relief, and predictable enforcement. Collaboration across international forums can align standards for risk disclosure, capital adequacy, and operational resilience. At the same time, banks must invest in scalable compliance architectures, governance reforms, and staff training to manage evolving sanctions landscapes. The objective is to preserve financial stability while maintaining the strategic leverage sanctions intend to deliver.
Ultimately, the health of the international banking system depends on a disciplined balance between deterrence and resilience. When sanctions are designed with consideration for systemic risk, they can achieve policy goals without triggering widespread instability. Strong governance, transparent communication, and proactive risk management enable institutions to absorb shocks and continue serving customers amid geopolitical shifts. By prioritizing collaboration among regulators, financial institutions, and market participants, the global financial architecture can better withstand the pressures of sanctions while sustaining the flow of legitimate trade and capital. The result is a more resilient, trustworthy, and orderly international financial system.
