Overview
Law360 quoted Alexandra Baj and David Stetson in a February 24 article titled, "Russia Sanctions Bring Compliance Headaches For US Banks."
The article covers how the US sanctions against Russia for invading Ukraine may impact American financial institutions, including potential steep costs and compliance burdens as they're quickly forced to screen and report on a complex network of blacklisted regions, entities, and individuals.
Baj explains, "When you have an expansion of a [sanctions] program — any time you're increasing the volume and complexity — you will need more resources to tackle that." She added that "when it comes to screening the transactions of Russian elites, the task becomes particularly tricky and burdensome."
Stetson continued, "The biggest resource demand is the effort to rapidly identify every exposure to one of these new sanctions targets, lock it down, freeze it and prevent them from, say, making a withdrawal from an account. The reporting requirements are the tail end of that once you've found the exposure and have locked it down."
The full article can be read at Law360 (subscription required).