White Paper: US Sanctions Enforcement on the Rise

Russia’s war on Ukraine and the unprecedented speed and volume of sanctions imposed on Russian leaders, banks, and other entities in the aftermath of the invasion 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.

US companies and financial institutions must not only work to ensure that their clients and potential business partners are not connected to sanctioned entities and individuals, but also research their supply chains, sellers, and resellers to confirm that they are not linked to or providing US-origin products and technologies to prohibited entities.

Although Russia’s invasion was the catalyst for the significant increase in designations, regulators expect a higher level of compliance with all sanctions programs. Taking a bare-minimum approach to compliance can leave companies vulnerable to risks that can damage their business.

Conducting thorough due diligence research is more important than ever.

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.

Companies that fail to effectively implement strong compliance processes are at risk of significant fines and reputational damage.

Read FiveBy’s research on increased US sanctions enforcement efforts and how they can impact your company, as well as how US firms and financial institutions can mitigate those risks below.


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