SANCTIONS COPILOT™ — The Tool

The Only Sanctions Program
Benchmarking Tool Built by
a Practitioner

SANCTIONS COPILOT™ is a self-assessment software tool for risk assessment, business analysis, audit and audit planning of sanctions compliance programs — across TradFi, fintech, payments, and digital asset institutions.

SANCTIONS COPILOT™ is a service mark of Sanctions Risk Institute LLC. USPTO Serial No. 98545968.

What You Get

Purpose-Built for Program Assessment

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14-Domain Scored Assessment

Comprehensive coverage across all five OFAC Framework pillars plus enforcement-anchored control domains specific to your institution type.

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Maturity Rating

Receive a clear Defined, Structured, or Optimized maturity rating — the same model used by top-tier compliance programs globally.

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Downloadable PDF Report

Your results generate a formatted PDF report suitable for internal use, board reporting, and examiner readiness documentation.

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Zero Data Retention

Your responses are never transmitted, stored, or seen by anyone. The tool runs entirely client-side. Your assessment is yours alone.

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All Institution Types

Covers TradFi, fintech, payment processors, and virtual asset service providers (VASPs). Select your institution type at the start.

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Enforcement-Anchored

Questions are anchored to real OFAC enforcement actions and settlements — not theoretical frameworks. Know what actually gets penalized.

Methodology

The OFAC Framework — Plus What Regulators Actually Expect

SANCTIONS COPILOT™ measures your program against the five essential components of every sound sanctions compliance program as defined by OFAC — then layers in the enforcement-specific benchmarks that separate programs that survive examinations from those that don't.

  • 01

    Management Commitment

    Senior leadership tone, resources, and accountability structures benchmarked against OFAC Framework and industry standards.

  • 02

    Sanctions Risk Assessment

    Coverage of customers, products, geographies, and transaction types — including VCG-specific digital asset risk factors.

  • 03

    Internal Controls

    Screening controls, geo-risk validation, blockchain monitoring, and systemic process controls benchmarked against enforcement history.

  • 04

    Testing & Auditing

    Independent audit, targeted testing protocols, and validation frameworks aligned with VCG and industry best practices.

  • 05

    Training

    Role-based training coverage, frequency, and effectiveness measurement benchmarked across TradFi and VASP industry standards.

14 Scorecard Domains

What Gets Assessed

OFAC VCG Digital Services CoverageClass 42
Enforcement Root Cause AnalysisOFAC
Geo Risk ValidationControls
Geo Keyword ScreeningControls
Blockchain Monitoring CoverageVCG
Senior Management CommitmentPillar 1
Sanctions Risk AssessmentPillar 2
Internal Controls — OFAC VCGPillar 3
Internal Controls — Industry BenchmarksPillar 3
Testing & Auditing — VCGPillar 4
Testing & Auditing — IndustryPillar 4
Training CoveragePillar 5
NL DNB Crypto Best PracticesGlobal
UK FCA Sanctions Best PracticesGlobal

Developed By

Crystal Noe — Founder & CEO, Sanctions Risk Institute

Crystal Noe is a sanctions compliance practitioner with 26+ years of experience across Tier-1 banks, Big Tech, fintech, and digital asset companies. SANCTIONS COPILOT™ was built from her direct experience developing, benchmarking, and remediating sanctions compliance programs at institutions operating under OFAC, OFSI, NYDFS, and DOJ scrutiny.

Author · Screen This, Avoid That · Sanctions Risk Institute LLC

Ready to assess your program?

Purchase SANCTIONS COPILOT™ or request more information.

SANCTIONS COPILOT™ is a service mark of Sanctions Risk Institute LLC. USPTO Serial No. 98545968. All rights reserved.