Alert: Enforcement on the Rise

Courtesy of

FiveBy recently published a white paper recommending that US firms and financial institutions enhance their compliance programs in anticipation of the US government’s increased focus on enforcement to counter sanctions evasion.

Ahead of the anniversary of Russia’s invasion of Ukraine, US Treasury Deputy Secretary Wally Adeyemo met with a group of sanctions and foreign policy experts to discuss the effects and successes of the unprecedented sanctions and export controls that have been imposed on Russia since the incursion began. Adeyemo flagged that Treasury in the months ahead will increase its focus on enforcement, countering sanctions evasion to continue hampering Russia’s ability to fund its military, procure equipment, and use technology in its war effort.

The readout of the meeting confirmed our assessment that simple list screening will no longer be enough. Regulators expect 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.

Download a free copy of the white paper HERE and watch this space for an upcoming webcast on the topic.

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