Targeting Russia’s IT Dependencies
Delve into the recent determination issued by OFAC, which imposes significant additional restrictions on the provision to Russia of IT consultancy and design services as well as IT support and cloud-based services of enterprise management and design and manufacturing software. Multinational tech corporations, financial institutions, and other companies still operating in Russia will likely require licenses to continue operating there.
OFAC’s Compliance Guidance in Action
The Treasury Department’s Office of Foreign Assets Control (OFAC) five years ago published its Framework for OFAC Compliance Commitments. This guidance remains the most comprehensive articulation of OFAC’s compliance expectations to date. Although it notably stopped short of mandating a sanctions compliance program (SCP), recent enforcement actions demonstrate the implications of not having an SCP in place.
Russian Use of Crypto for Sanctions Evasion on the Rise
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.
Counterproliferation Finance Detection and Deterrence – What Can Financial Institutions Do?
The U.S. Treasury recently identified proliferation networks operating on behalf of Russia, North Korea, China, Iran, Syria, and Pakistan as threats to U.S. national security. These networks exploited the U.S. financial system to finance the proliferation of weapons of mass destruction (WMD), including financing to procure WMD components and raising revenues to support efforts by these state actors to advance their WMD activities.
Russia Sanctions Evasion Case Study: Viktor Labin
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When conducting customer due diligence and enhanced due diligence, simple screening for names that may be on sanctions lists is no longer sufficient given the increasing complexity of Russia’s sanctions evasion efforts and the volatile regulatory environment because of Moscow’s aggression against Ukraine. Extra research is necessary to ensure compliance with sanctions laws and adherence with your company’s own risk policies. This research, however, can be complex, and structured analytic techniques and tools are necessary for effective due diligence.
Thanks to Russia, Cross-Border Sanctions Collaboration at All-Time High
Russia's unprovoked invasion and continued aggression in Ukraine has led to an unprecedented level of collaboration by sanctions stakeholders across jurisdictions, agencies, and sectors. IFI is publishing a series of blogs to highlight this increased collaboration. In this first blog, we take a look at cooperation across borders and most notably by the REPO Task Force and Price Cap Coalition.
Ukraine’s War on Two Fronts – Fighting Corruption Amidst Russia’s Continued Attacks
As the second anniversary of Russia’s full-scale war of aggression in Ukraine approaches, winning on the battlefield remains the top mission objective for the Armed Forces of Ukraine, the Ukrainian people, and Ukraine’s international partners. While the full-scale invasion began two years ago, addressing systemic governmental and economic corruption has been an enduring battle for Ukraine since it gained its independence from the Soviet Union in 1991.
Exhausting Russian Resources by Sanctioning Western Software
Despite the Kremlin's attempts to reduce reliance on Western software for crucial systems, this transition is advancing slowly, presenting significant opportunities to hinder Russia's military effectiveness and economic activities. Read on for more information on the current role of Western technology and guidance for governments and companies formulating sanctions proposals.
Evading Export Controls – Russia’s Key to Success
Russia has used third-party intermediaries to evade sanctions and export controls for years and has disguised the involvement of SDNs or sanctioned entities in transactions to obscure the true identities of end users. This activity has increased since Russia’s invasion of Ukraine in 2022 due to Russia’s need for military equipment.
How to Avoid Becoming an Unwitting Facilitator of Russian Sanctions Evasion
What steps can organizations take to avoid becoming unwitting suppliers of critical components and tools for the Russian military?