The financial technology, or "fintech" sector has grown dramatically in recent years. The number of new fintechs increased by more than 70% globally between 2019 and 2020 as the COVID-19 pandemic hastened technology adoption.  With this rapid rise in technological innovation, sanctions compliance officers are encountering novel challenges which are exacerbated both by 1) the inherent features of fintech solutions, such as reduced customer friction, seemingly borderless payments, and a reliance on a complex network of underlying financial partners; and 2) an increasingly unstable geopolitical climate that has resulted in ramped up complex sanctions and unique sanctions evasion techniques.  With this in mind, sanctions compliance officers in the fintech sector may be wondering how to develop and maintain a purpose-built sanctions compliance program tailored to their unique risk profile.  We share below some best practices for fintech sanctions compliance programs, leveraging our experience working with fintech firms across the world and guidance documents published by various authorities namely the U.S. Office of Foreign Assets Control’s ("OFAC") Framework for Compliance Commitments. This article’s goal is to help compliance professions in fintech firms globally build or improve their sanctions compliance set-up.

In July 2023 the Dutch government announced its intention to join the multilateral Agreement on the Control of Arms Exports between France, Germany, and Spain. The letter carrying the announcement simultaneously repealed the existing Dutch presumption of denial policy regarding arms exports to Saudi-Arabia, Turkey, and the United Arab Emirates. This article analyses these developments within the broader framework of the Netherlands and EU arms export controls. Its aim is to introduce the readers to challenges facing EU arms export controls, to explain the reasoning behind the Netherlands’ decision to join the agreement, and to describe some of the potential practical implications for the Dutch defence and security sector. The article finds that while the EU has been working towards a common European approach to arms export controls for over three decades, the EU Common Position (1st introduced in 2008) did not achieve the desired convergence on arms export policies.