As a result of the conflict in Ukraine and the unprecedented imposition of sanctions which followed, in March 2022, the Financial Conduct Authority (FCA) laid down a clear marker that policing sanctions compliance is a high priority for it and stressed that ‘Where the FCA identifies failings in financial crime systems and controls we can impose restrictions and/or take enforcement action.’ This Q&A considers what this means for senior managers and the standard expected of them in order to discharge their personal regulatory duties under the Senior Managers and Certification Regime (SM&CR) in relation to sanctions compliance.