Risk is perceived to be higher when a subject area is unfamiliar, which is particularly likely for emerging technologies and products. One solution is to develop the capability of staff through training and experience, where Chief Compliance Officers can utilize partners to support upskilling and augment internal capability where required. Digital assets provide a good case study: detailed knowledge within financial institution compliance and business teams to manage risks while enabling business growth.

Experts agree there isn't enough liquidity in the virtual assets space to enable largescale sanctions evasion by Moscow, but sanctioned individuals and entities have used virtual currencies—most notably Tether—to access the global financial system and pay for restricted goods and technologies. Explore recent designations, how cryptocurrencies and other virtual assets are being leveraged to facilitate evasion as well as risk mitigation strategies for financial institutions in our latest article.

OFAC in 2023 reached settlements with 17 companies, collecting more than $1.5 billion in penalties. Mitigating factors can help reduce the severity of penalties imposed by OFAC for sanctions violations and often involve significant remedial measures and enhancements to a company’s sanctions compliance program.