Managing Russia sanctions

Abstract

Sanctions related to Russia continue to increase in volume and detail, bringing greater compliance complexity and cost. This paper focuses on US and EU sanctions. It looks at three aspects any company engaging in Russian-related business needs to consider. Understanding its Russian business in the sense of which parts of the company are doing business, with whom and about what; understanding the sanctions risks relating to its Russian business in the sense of which sanctions are in scope and what is prohibited; and lastly understanding the compliance challenges of its Russian business. The specific compliance challenges considered are banking arrangements, exposure to the US financial system, capital markets transactions, identifying sanctioned Russian individuals and entities, interacting with Russian clients, sectoral sanctions, US secondary sanctions and further sanctions. By taking account of these aspects, any company should be better placed to manage Russia sanctions rather than be managed by them.