The Compliance Corner Podcast Episode 2: One SME’s sanctions experience - A conversation with Maria Mougianni

Intro 

Welcome to the EU Sanctions Helpdesk Compliance Corner Podcast. In this series, we get deep into the EU sanctions landscape, all with a focus on helping SMEs with their sanctions compliance. The EU Sanctions Helpdesk is an initiative created by the European Commission. It supports SMEs by providing essential guidance and resources to navigate sanctions compliance and tackle related challenges in their daily business activities.

Podcast host Dimitrios Chaidas 

The new episode of the Compliance Corner is here, and it's a special one, because I'm joined by someone who brings a wealth of experience and a fascinating real-world perspective to our conversation. I am Dimitrios Chaidas, key expert on communication at the EU Sanctions Helpdesk. And my guest today is Maria Mougianni, representing a Greek SME that recently took part in our free personalised due diligence support service. 

A few words about our guest. Maria Mougianni is the head of compliance at HarborLab, where she's been leading the company's compliance framework for the past three years. She brings more than 20 years of international experience in financial services, with a focus on sanctions governance and enforcement in the maritime industry, as well as regulatory strategy and risk management. Maria is also known for bringing a data-driven approach to compliance. Maria, welcome and thank you for joining me and our listeners. 

Maria Mougianni  

Thank you. 

Dimitrios Chaidas 

I have to admit that I've been looking forward to our discussion, as this is the first podcast episode featuring a beneficiary of our Helpdesk Support Service. Now, let's kick things off with a little background. 

Please, Maria, tell us about the company and its activities. 

Maria Mougianni 

HarborLab is a pioneering B2B maritime technology company founded in Athens, Greece, in 2020. We are dedicated to transforming port cost management through a purpose-built AI-powered software as a service platform. Our core offering enables shipping companies, including ship owners and charterers, to manage a DA, that means a disbursement account process, with transparency, consistency and operational control across thousands of port calls worldwide. 

Our platform automates and streamlines the end-to-end DA lifecycle, helping maritime stakeholders reduce administrative complexity, ensure cost accuracy and strengthen financial accountability. 

Dimitrios Chaidas 

Thank you for this introduction, Maria. I would like to ask you what have been the main challenges that the company has faced so far. I would like to understand, for example, a little bit the context, to have an idea, you know, what led you and HarborLab to the Helpdesk and the support service that we offer. 

Maria Mougianni 

The main challenges we have faced stem from the complexity and constant evolution of international sanctions in the maritime industry. As HarborLab supports global shipping operations, we must constantly adapt to legal, operational and reputational risks, especially those related to sanctions imposed by EU, UN, UK and US. These challenges we address include, first of all, navigating the evolving sanctions in the maritime sector. 

Maritime-related sanctions can include restrictions on vessel ownership, port calls and service delivery. These evolve very quickly and often unpredictably. HarborLab stays vigilant, ensuring our systems and policies remain synchronised with real-time changes. 

Another challenge is conflicting legal frameworks across jurisdictions. The differences between major sanctions regimes, in definitions, thresholds and enforcement practises add complexity. For example, different ownership disclosure thresholds are in the US and the EU, and this can influence how UBO screening is conducted. 

We have built our compliance logic to reflect and respond to such differences. Another one is maintaining real-time accuracy. Maritime-specific designation, vessel flags and beneficial owner disclosures change very frequently. To keep up, we run daily screening using trusted databases and incorporate real-time alerts into our risk workflows. 

Another one is achieving transparency in maritime networks. Ownership structures in shipping can be opaque. We implement structured onboarding processes and validate submitted documents, including certificates of competency, registry extracts and verified banking details. We also use third-party databases to reduce the burden on customers while maintaining a high verification standard. 

And finally, promoting global understanding of compliance. Not all counterparties understand the reasoning behind EU-level compliance. Some may view our due diligence procedures as excessive. We turn these moments into conversations and opportunities to share knowledge and uphold consistency. 

Dimitrios Chaidas 

That was insightful, Maria, thank you. If I got it right, you highlighted four main challenges. 

Accuracy, the evolving nature of sanctions, conflicting legal frameworks across jurisdictions, and the difficulty of achieving a global understanding of EU sanctions and compliance. Considering that navigating sanctions-related challenges may not be as straightforward for an SME as it could be for a large corporation, I would like to ask you what steps do you take at the company level to address the challenges you mentioned earlier? 

Maria Mougianni 

Recognising the increasing complexity of global sanctions and the need for jurisdictional agility, we take deliberate steps to build a resilient, transparent and risk-aware compliance framework that reinforces trust and ensures operational excellence across our network. This strategic vision is executed through key initiatives that translate our principles into action. And these key initiatives include, first of all, comprehensive onboarding procedures. 

We implement rigorous onboarding processes for all agents, vendors and shipping stakeholders. This includes UBO identification, corporate registration verification and sanctions list screening. By validating these criteria at the outset, we proactively reduce exposure to high-risk engagements and ensure a clean foundation for collaboration. 

Then we have automated and ongoing screening. To maintain continuous vigilance, we perform daily screening of all active entities using trusted external databases. This automation allows us to detect and respond to new sanctions development in real time, preserving the integrity of our ecosystem and reinforcing our commitment to transparency. 

Then, jurisdictional sensitive controls. Understanding that sanctions regimes across EU, US, UK and UN differ in scope, we designed our compliance checkpoints to be regionally adaptive. This enables us to tailor controls according to the applicable legal frameworks of our clients and partners, increasing both flexibility and relevance. 

And another initiative is the escalation protocols. We have established clear escalation paths for any positive and ambiguous screening result. These are escalated, first of all, to compliance department and where necessary to our risk committee for formal review. All outcomes are documented, ensuring procedural transparency and accountability. 

And finally, embedding compliance across teams. Compliance is not confined to a single team. It is embedded across all functions, from onboarding team to customer success and operations. We equip our teams with the knowledge to identify compliance triggers, take an active role in mitigating risk and adjust workflows to meet evolving regulatory requirements. This cross-functional ownership ensures that compliance is not merely a procedural application, but a deeply rooted aspect of our culture. 

Dimitrios Chaidas 

Maria, I have to say, even though I'm not a compliance expert, I feel I now have a much clearer picture of how you handle sanctions related challenges through the protocol you've put in place. As you know, here at the Compliance Corner, our goal is to raise awareness and give SMEs a voice to share their real-world experiences navigating the sanctions landscape. So for those SMEs listening right now, do you have any key tips or lessons learned you would like to share? 

Maria Mougianni 

The journey toward building a resilient and compliant business environment has taught us valuable lessons, both strategic and operational, that we believe can serve as inspiration for other SMEs, particularly for those navigating cross-border activity. 

First lesson is to treat compliance as a product feature. At HarborLab, compliance is not an afterthought. It's embedded into the user journey, internal workflows and our company culture. This helps us win trust with clients and institutional stakeholders. 

Another lesson is to prepare for constant change. Sanctions frameworks evolve quickly and without much warning. A flexible mindset and an adaptable internal architecture are key. This includes keeping policies under continuous review and ensuring companies teams are equipped to handle regulatory shifts. 

Another one is to leverage external expertise. One of the most impactful choices we made was to make full use of public resources like the EU Sanctions Helpdesk. Their guidance has been essential in validating our internal approach and clarifying how certain obligations apply to our business model. They have helped us navigate complex interpretations, for example, around ownership disclosures and jurisdictional applications, ensuring that our decisions are well-reasoned and appropriate. 

Another one is to invest in systems, but also in people. Technology, as we know, plays a crucial role, but it's the human oversight, the judgement of a trained and accountable team that ensures lasting compliance. 

And the last one is to create visibility and documentation from the start. Establish clear, consistent and well-documented compliance processes early on enables teams to operate with clarity, improves transparency and strengthens institutional memory, all of which are essential for continuity, confidence and credibility as our business grows. In short, I believe that SMEs should not wait for scale to build structure. Build structure early will support clarity, eligibility and long-term success. 

Dimitrios Chaidas 

You mentioned the EU Sanctions Helpdesk and really I cannot help but wonder about, you know, I would like to know a little bit about your experience with the Helpdesk. I think you were the contact point, you know, for the requests that you submitted to the Helpdesk. So I'm very curious and I would like to know how was your experience with the support service overall? 

Maria Mougianni 

The EU Sanctions Helpdesk has become an invaluable resource for SMEs like HarborLab. As a company navigating a complex regulatory environment across multiple jurisdictions, we have found that the EU Sanctions Helpdesk is a practical support mechanism that enhances the clarity, confidence and consistency of our compliance decisions. One of the greatest strengths lies in offering a highly informed, impartial and third-party perspective on regulatory interpretations. 

When internal questions arise or when guidance from traditional legal channels proves inconclusive, EU Sanctions Helpdesk provides a clear and trusted perspective that helps drive decisions forward. This is particularly important when dealing with ambiguous or evolving complications around ownership transparency, counterparty engagement or maritime-specific restrictions. In several cases, we reached out to the Helpdesk for clarification on due diligence thresholds and jurisdictional interpretation. 

The insights we received did not only confirm our compliance posture but they also helped validate our broader compliance framework. That external reassurance from a credible party strengthens the legitimacy of our internal processes and empowers us to maintain high standards. 

Additionally, the Helpdesk is accessible and responsive. Its availability, free of charge, removes a major barrier for smaller companies seeking informed guidance. This democratisation of expert compliance support is essential in helping SMEs build structured and scalable programmes. 

Dimitrios Chaidas 

That was great to hear, Maria. Thank you so much once again for joining me for this discussion. I'm sure that many SMEs, including SMEs in Greece, of course, that perhaps they have already used our support service or are considering using the service, will find your insights and experience both useful and inspiring. 

Thank you so much. 

Maria Mougianni 

Thank you so much, too. 

Outro

Thank you for listening to this episode of the Compliance Corner Podcast. Are you an SME with questions about sanctions? Then make sure to take advantage of our free customised support service found at eu-sanctions-compliance-helpdesk.europa.eu.