Russia’s war on Ukraine and the subsequent unprecedented speed and volume of sanctions imposed on Russian leaders, banks, and other entities have drastically altered US sanctions and anti-money laundering (AML) enforcement efforts, pointing a laser focus on individuals and entities concealing the origins of funds, hiding assets for sanctioned individuals and entities, and facilitating malign actors’ access to the global financial system and restricted tools and technologies.
The United States is pouring unprecedented resources into sanctions enforcement.
How can US firms and financial institutions adjust?
Simple list screening is no longer enough. Regulators are looking for robust compliance programs that research, monitor, and take risk-appropriate actions to ensure that malign actors do not access US tools, technologies, and the financial system writ large.
US companies and financial institutions must also research supply chains, sellers, and resellers to confirm that they are not linked or providing US-origin products and technologies to prohibited entities.
Family members, close associates, attorneys, management companies, and financial advisors are just some of the individuals and entities that can help those sanctioned by the United States, UK, EU and others move and conceal assets.