Associate | White Collar Defense and Investigations
We have been closely monitoring the sanctions landscape over the last few months. Back in March, we covered the sanctions levied by the United States and other jurisdictions in response to Russia’s invasion of Ukraine. The sanctions impair Russia’s ability to access the international financial system and are designed to have a severe and lasting effect on Russia’s ability to fund the war in Ukraine and other such initiatives. Sanctions are serious business and may result in strict liability, meaning that a financial institution or other party can be liable for a sanctions violation even if there is no knowledge of or intent to commit a violation. When it comes to managing risk, most financial institutions consider sanctions risk in terms of the parties with whom they interface directly.
