In line with the second anniversary of Russia’s invasion of Ukraine the United States, European Union and United Kingdom have all added to their sanctions lists.
- The EU’s recently adopted 13th package of sanctions against Russia adds 106 individuals and 88 entities to the sanctions list, bringing total listings to in excess of 2000.
- In the US, The Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned nearly 300 additional individuals and entities. Together with actions from the US Department of State this is the largest number of sanctions imposed since the start of the invasion bringing the total to over 4000.
- The UK has added over 50 new sanctions targeting individual and businesses bringing the total number of individuals, companies and groups under the UK’s Russia sanctions regime to 2000.
Collectively these recent actions demonstrate the ongoing challenge for financial institutions when it comes to keeping abreast of the latest Russia related sanctions, and other sanctions around the globe.
Since the first round of Russian sanctions was introduced, regulators have removed the requirement to demonstrate that a person or organisation had knowledge or reasonable cause to suspect they were in breach of a financial sanctions in order to issue a penalty. This places the onus on financial institutions to ensure they have adequate compliance procedures in place, as well as ready access to up to date and accurate information on all counterparties. Relying on banks to catch sanctioned persons at either the onboarding or transaction stage, is no longer a viable option, jeopardising these relationships and potentially leaving firms open to penalties for breaches.
IDR’s internationally compliant KYC service provides a complete solution for private markets fund managers and investors. Beginning with the identification and verification of all beneficial owners we then create a digital due diligence profile on our central hub. This is kept up to date with live ongoing sanctions screening ensuring compliance with all the latest sanctions and enforcement rules.
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