Last Updated 05-19-22

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May 2022

  • The UK sanctions additional Russian individuals reportedly close to President Putin, including his ex-wife and cousins.
  • Russia blocks transactions with 31 foreign energy companies, including ex-subsidiaries of Gazprom in the EU, as well as firms in the US and Singapore.
  • Japan announces it will freeze assets of 8 Russian officials, ban all exports to 71 Russian organizations, and ban exports of “cutting edge goods” to Russia.
  • New Zealand announces financial sanctions against 8 Russian individuals and entities involved in disinformation campaigns and cyber attacks on Ukraine.
  • The US temporarily suspends its import tariffs imposed by the Trump administration under Section 232–the “national security tariffs”–on Ukrainian steel for one year.
  • The UK imposes new import tariffs on £1.4 billion worth of goods–including platinum and palladium–and new export bans covering £250 million worth of goods such as chemicals, plastics, rubber, and machinery.
  • Following the G7 announcement, the US Treasury and State Departments announce new sanctions, including a ban on exports of accounting, trust, and corporate formation, and management consulting services. The US also imposes financial sanctions and visa restrictions on Russian bank executives and other individuals, defense companies, and state-owned television stations.
  • To commemorate the end of the Second World War in Europe, G7 leaders state forthcoming sanctions will include phasing out dependence on Russian energy; export bans on key services; additional sanctions against Russian banks, oligarchs, and individuals; and efforts to fight off Russia’s propaganda.
  • Canada sanctions additional Russian individuals and companies.
  • The UK announces financial sanctions on Evraz plc, a Russian steel manufacturing and mining company.
  • The UK announces a ban on services exports to Russia, including management consulting, accounting and public relations.It also freezes the assets of and imposes travel bans on 63 individuals and entities associated with the “Kremlin’s shadowy troll factory tactics.”
  • Australia imposes financial sanctions and travel bans on 110 individuals, including Ukrainian separatists and members of Russia’s parliament.
  • Canada sanctions additional Russian individuals and amends language in sanctions regulations.
  • The UK announces financial sanctions on Evraz plc, a Russian steel manufacturing and mining company.
  • The UK announces a ban on services exports to Russia, including management consulting, accounting and public relations.It also freezes the assets of and imposes travel bans on 63 individuals and entities associated with the “Kremlin’s shadowy troll factory tactics.”
  • Australia imposes financial sanctions and travel bans on 110 individuals, including Ukrainian separatists and members of Russia’s parliament.
  • New Zealand imposes financial sanctions and travel bans on Russian politicians and sanctions 6 companies in the Russian defense industry.

April 2022

  • Switzerland implements most of the remaining EU sanctions in the package announced on April 8.
  • Russian energy company Gazprom cuts off natural gas exports to Poland and Bulgaria over their refusal to pay in rubles.
  • China cuts its applied MFN tariffs on coal imports to zero from 3-6 percent in a controversial move anticipated to disproportionately benefit Russian exports displaced from other markets.
  • The UK announces it will cut tariffs to zero on all imports from Ukraine. It also plans to ban exports of certain products and technology to Russia, such as interception and monitoring equipment.
  • The US prohibits Russian-affiliated vessels from entering US ports.
  • The EU freezes assets and bans travel for two separatists involved in Russia’s annexation of Crimea and destabilization of eastern Ukraine.
  • The UK bans imports of additional Russian goods, including silver, wood products, and caviar, and imposes an additional 35 percent import tariff on other imports from Russia and Belarus, including diamonds and rubber. The UK also imposes financial sanctions and travel bans on a number of Russian military commanders and others supporting Putin’s war.
  • Newly re-elected President Aleksandar Vucic states that Serbia, a candidate for EU membership, will not impose sanctions on Russia because “we don’t believe sanctions change anything. You can pressure and force Serbia but this is our genuine opinion.”
  • The Russian Foreign Ministry blacklists 29 Americans, including Vice President Kamala Harris and Meta CEO Mark Zuckerberg.
  • Australia imposes sanctions on Putin’s and Lavrov’s daughters as well as more Russian politicians.
  • The US Treasury sanctions entities and individuals involved in attempts to evade US sanctions. They include Transkapitalbank, Bitriver, and other companies in Russia’s virtual currency mining industry, and a network led by Russian oligarch Konstantin Malofeyev. The US State Department also announces visa restrictions on hundreds of individuals.
  • In another action following the March 11 joint announcement, Japan passes a law withdrawing MFN tariff treatment for imports from Russia, which will raise import tariffs for certain products.
  • Canada sanctions Russian Central Bank Governor Elvira Nabiullina, Putin’s daughters, and other Russians.
  • The UK’s tax authority announces it will revoke the Moscow Stock Exchange’s status as a recognized stock exchange, depriving future investors of access to certain UK tax benefits.
  • New Zealand sanctions 18 Russian banks and financial institutions, including the Central Bank of Russia, Sberbank, Alfa-Bank, and more.
  • The UK sanctions additional Russian oligarchs, and its Parliament passes legislation banning imports of Russian iron and steel and exports to Russia of quantum technologies and advanced materials.
  • The European Council introduces exceptions to some EU sanctions to mitigate the humanitarian crisis caused by Russia’s invasion of Ukraine.
  • The UK imposes financial sanctions on 206 individuals, including 178 separatists of the so-called Donetsk and Luhansk People’s Republics, six Russian oligarchs, as well their close associates and employees.
  • Switzerland sanctions Russia and Belarus by adopting the EU’s fifth round of sanctions announced on April 8, as well as issuing other amendments. Switzerland claims its list of sanctions “now fully mirrors that of the EU.”
  • Australia imposes sanctions on 14 additional Russian state-owned enterprises.
  • Adhering to the April 6 joint announcement, Japan bans imports of certain Russian products, prohibits new foreign direct investment in Russia, and imposes financial sanctions on 398 Russian individuals (including Putin’s daughters) and 28 Russian entities (including Sberbank and Alfa-Bank).
  • US Department of Commerce expands the license requirements on export controls applied to Russia and Belarus to all items on the Commerce Control List (CCL).
  • Canada imposes financial sanctions on an additional 33 entities in Russia’s defense sector.
  • US Department of Commerce adds Iceland, Liechtenstein, Norway, and Switzerland to the list of countries excluded from the license requirements under its Russia/Belarus Sanctions rules (imposed on February 24 and March 2), including the Foreign Direct Product Rule. They join EU member states, Japan, South Korea, Canada, Australia, UK, and New Zealand.
  • Biden administration signs two bills into law. The “Ending Importation of Russian Oil Act” (H.R. 6968) prohibits energy imports from Russia, and the “Suspending Normal Trade Relations with Russia and Belarus Act” (H.R. 7108) raises US tariffs toward each country to their rates in column 2 of the Harmonized Tariff Schedule.
  • The UK announces financial sanctions targeting the daughters of Putin and Lavrov.
  • Adhering to the April 6 joint announcement, the EU imposes its fifth major package of sanctions. It bans imports of Russian coal starting in August 2022 and other products such as wood, cement, fertilizers, seafood, and liquor. It expands export bans to include jet fuel, quantum computers, semiconductors, and other technology products and services. It prohibits Russian vessels from accessing EU ports as well as Russian and Belarusian vehicles from using EU roads. It imposes a full transactions ban on 4 more Russian banks and imposes financial sanctions on Russian oligarchs, politicians, and their family members, including Putin’s daughters. It also bans Russian companies from EU public procurement projects.
  • The US Treasury sanctions Alrosa, Russia’s largest diamond mining company. The US State Department sanctions United Shipbuilding Corporation, a major Russian company responsible for building Russian navy warships.
  • In its first enforcement action, the US Department of Commerce issues temporary denial orders (TDOs) revoking export privileges of 3 Russian airlines–Aeroflot, Azur Air, and UTair–for alleged violations of earlier US export controls.
  • In response to revelations of Russian atrocities in Bucha, Australia imposes financial sanctions and travel bans on more Russian oligarchs.
  • Following the G7 and EU announcement, the Biden administration issues an Executive Order (EO 14071) banning new outbound US foreign investment into Russia as well as services exports. The US Treasury also imposes financial sanctions on Sberbank, Alfa-Bank, and family members of Putin, Lavrov, and Russian Security Council members.
  • Following the G7 and EU announcement, the UK imposes financial sanctions on Sberbank, Credit Bank of Moscow, and 8 oligarchs. The UK also bans all new outward investment to Russia, bans imports of Russian iron and steel products, commits to end imports of Russian coal and oil by the end of 2022 and gas “as soon as possible thereafter,” and bans exports to Russia of quantum and advanced material technologies.
  • In response to revelations of Russian atrocities in the city of Bucha in Ukraine, the G7 and EU announce plans to document and share information about the atrocities and to impose more economic costs on Russia, including through additional sanctions. Early the next day, their foreign ministers issue a joint statement condemning the atrocities and welcoming investigations into Russia’s potential war crimes and crimes against humanity.
  • New Zealand will apply a 35 percent tariff on all imports from Russia and extend its export ban to new products such as ICT equipment and engines.
  • Canada prohibits exports of insurance services for the Russian aircraft, aviation, and aerospace industry and sanctions additional Russian oligarchs.
  • US Treasury sanctions two Russian entities: Hydra, the world’s largest darknet market, and Garantex, a ransomware-enabling virtual currency exchange.
  • New Zealand imposes sanctions on 36 Russian oligarchs and their family members.
  • Australia bans exports of certain luxury goods to Russia.
  • The US Department of Commerce expands export controls by adding to the Entity List 120 Russian and Belarusian firms alleged to support the two countries’ militaries.

 

March 31st

  • Australia announces it will withdraw MFN tariff treatment and apply an additional tariff of 35 percent to all imports from Russia and Belarus starting April 25.
  • The UK sanctions Russian individuals and state media “who spread lies and deceit about Putin’s illegal invasion of Ukraine.”
  • US Treasury expands financial sanctions on 21 entities and 13 individuals to prevent Russia from evading earlier sanctions and acquiring foreign technology. Treasury also expands sanctions under EO 14024 to include aerospace, marine, and electronics sectors.
  • Putin signs a decree forcing gas payments to be made in rubles if buyers are from “unfriendly” countries, including western Europe.

March 30th

  • The UK Parliament passes legislation to prohibit maintenance on aircraft or ships belonging to specific sanctioned Russian oligarchs or their businesses and immediately uses the new laws to sanction two additional individuals. The legislation also extends earlier finance, trade, and shipping sanctions imposed on Crimea to Donetsk and Luhansk.

March 29th

  • Japan revises the list of luxury goods for which it originally banned exports to Russia on March 25.

March 28th

  • For the purposes of General Licence INT/2022/1438977 the DP is Russian Railways. The Joint Venture is GEFCO, a Joint Venture owned by Russian Railways and Stellantis, GEFCO S.A Rue Jean Jaures, 20-22, 92800 Puteaux, France.
  • A Subsidiary is any entity owned or controlled by the DP, including:
    – GEFCO UK Ltd
    – GEFCO Forwarding UK
    – Auto XP Limited
    – XP Tech Limited

March 25th

  • The Federal Council implemented further goods and financial sanctions against Russia.

March 24th 

  • Group of 7 (G7) and EU leaders meet at NATO headquarters in Brussels and commit to fully implement sanctions already announced, work with other governments to impose similar sanctions, and prevent “evasion, circumvention and backfilling” that would undercut the effectiveness of already imposed sanctions. Leaders announce a joint initiative to respond “to evasive measures, including regarding gold transactions by the Central Bank of Russia.”
  • UK announces new sanctions targeting Russian defense and other strategic industries, additional Russian banks, and individual businesspeople.
  • Froze more than $6 billion worth of sanctioned Russian assets
  • Following the G7 announcement, the US Treasury sanctions dozens of Russian defense companies, 328 members of the Russian Duma, and other Russian individuals. It also clarifies that existing US sanctions cover any transactions involving gold and the Central Bank of Russia.

March 19th 

  • Australia banned exports of alumina to Russia, which is needed to produce aluminum.

March 18th 

  • Japan added sanctions against 15 Russian individuals and 9 Entities
  • Switzerland sanctions Russia by adopting the EU sanctions announced on March 15, including financial sanctions on 197 individuals and 9 entities, and an export ban on luxury goods. Switzerland will first do its own analysis before deciding whether to withdraw MFN import tariff treatment toward Russia.
  • In an enforcement warning, the US publicly identifies dozens of commercial and private flights from third countries to Russia since March 2 that it claims were in violation of new US export controls on Russia or Belarus.
  • Australian Government placed sanctions on 11 additional Russian banks and government entities

March 17th

  • Australia announces sanctions against Russian individuals, banks, and government entities.
  • The UK suspends exchange of tax information with Russia and Belarus.

March 15th

  • The United Kingdom – The UK Government announced a ban on exports to Russia of high-end luxury goods, while also hitting hundreds of key products with new import tariffs. 9 entries have been added to the consolidated list and are now subject to a cyber sanctions asset freeze, 8 individuals and 1 Entity. Financial sanctions: Added, 377 Individuals; 10 Entities; & Amended 6 Entries.
  • United States – SANCTIONS DESIGNATION: 11 Senior Russian Defense Officials; Office of Foreign Assets Control ADDED to Specially Designated Nationals List [SDN List]: 10 Individuals to RUSSIA-EO14024; 1 Individual to BELARUS; 4 Individuals to MAGNIT; 1 Entity to MAGNIT; Updated 1 records for Belarus; Updated 1 record for RUSSIA-EO14024
  • European Union – Russia’s military aggression against Ukraine: Added 15 individuals and 9 Entities
  • Canada – Special Economic Measures: 15 Russian Officials added

March 14th

  • Singapore – Added financial sanctions and restrictions on doing business in Russia.
  • Australia – Designated Persons and Entities and Declared Persons—Russia and Ukraine – 33 Individuals added

March 11th

  • United States – Restrictions imposed that applies to luxury goods or any Russian or Belarusian oligarch or malign actor, regardless of location, who are designated on the Department of the Treasury, Office of Foreign Assets Control’s (OFAC) List of Specially Designated Nationals and Blocked Persons (SDN List) with any of the following designations: [RUSSIA-EO14024], [UKRAINE-EO13660], [UKRAINEEO13661], [UKRAINE-EO13662], [UKRAINE-EO13685], [BELARUS], and [BELARUSEO14038] or in situations in which any such Russian or Belarusian oligarch or malign actor is a party to the transaction as described in § 748.5(c) through (f). For purposes of this paragraph (a)(2), an ‘oligarch or malign actor’ is any natural person that is designated on the SDN List with any of the designations referenced in this paragraph (a)(2).
    • The President has signed a new Russia-related Executive Order Prohibiting Certain Imports, Exports, and New Investment with Respect to Continued Russian Federation Aggression.
    • RUSSIA-RELATED GENERAL LICENSE NO. 17
      RUSSIA-RELATED GENERAL LICENSE NO. 18
      RUSSIA-RELATED GENERAL LICENSE NO. 19
      UKRAINE-RELATED GENERAL LICENSE NO.23
    • Specially Designated Nationals List [SDN List] added 35 Individuals, 3 Entities, 1 Vessel, 1 Aircraft + 8 records amended (6 individuals & 2 Entities)
  • The United Kingdom – 386 individuals have been added to the consolidated list. The 386 are members of the State Duma of the Russian Federation and are now subject to an asset freeze. The full list of names are located here. 15 entries have been amended on the consolidated list and remain subject to an asset freeze (10 individuals & 5 Entities).

March 10th

  • The United Kingdom – The following entries have been amended on the consolidated list and are still subject to an asset freeze:
      Celestino De Carvalho (Group ID: 12678)
      Antonio Injai (Group ID: 12664)
      Augusto Mario Co (Group ID: 12666)
      Daba Naualna (Group ID: 12669)
      Mamadu Ture (Group ID: 12665)
      Roman Arkadyevich Abramovich (Group ID: 14212)
      Igor Ivanovich Sechin (Group ID: 14213)
      Oleg Vladimirovich Deripaska (Group ID: 14214)
      Dmitri Alekseevich Lebedev (Group ID: 14215)
      Alexei Borisovich Miller (Group ID: 14216)
      Andrei Leonidovich Kostin (Group ID: 14217)
      Nikolai Petrovich Tokarev (Group ID: 14218)
  • General Licence INT/2022/1327076 pertains to the continuing operation of Chelsea Football Club

March 8th

  • Australia – Department of Foreign Affairs and Trade [DFAT] and the Australian Sanctions Office [ASO]– Updated the consolidated list, Autonomous Sanctions (Designated Persons and Entities and Declared Persons – Russia and Ukraine) Amendment (No.4 and 5) Instrument 2022, which adds sanctions against Individuals and entities in the Russia/Ukraine situation.
  • United States – Office of Foreign Assets Control [OFAC] – Issued a new Executive Order Prohibiting Certain Imports and New Investments With Respect To Continued Russian Federation Efforts To Undermine the Sovereignty and Territorial Integrity of Ukraine.

March 7th

  • Canada announced they are adding 10 new Russian individuals to its sanctions list who are “complicit” in the Russian invasion of Ukraine. Which includes former and current senior government officials, oligarchs, and supporters of the Russian leadership
  • New Zealand published a travel ban list of over 100 individuals associated with the Russian invasion of Ukraine (Source Information attached)
  • New Zealand announced that it will introduce legislation to allow it to bring first-of-its-kind sanctions against Russia following its invasion of Ukraine. The sanctions will give the country the ability to freeze Russian assets in New Zealand, prevent people and companies from moving their money and assets here to escape sanctions imposed by other countries, and stop superyachts, ships, and aircraft from entering the country’s waters or airspace. New Zealand has previously only been able to implement sanctions when the United Nations Security Council has imposed them. The Security Council will not be able to impose sanctions against Russia as Russia has the power to veto them. The Russia Sanctions Bill will pass under urgency this week, to provide further, extensive sanctions on Russia in response to the invasion of Ukraine.
  • Japan is in discussions with the US and European countries about possibly banning Russian oil imports
  • South Korea has decided to sever transactions with Russia’s central bank
  • OFAC added a terrorist entity
  • The sanction database SESAM (SECO Sanctions Management), which is decisive for Switzerland, adapted the measures against Myanmar. The change took effect today, March 7th at 6 pm.

March 6th

  • The US government is consulting with its European allies on a potential import ban of oil from Russia.
  • American Express suspended operations in Russia and Belarus
  • Netflix halts service in Russia

March 5th

  • The EU has joined members of the Council of the Baltic Sea States (CBSS) in suspending Russia and Belarus from the Council’s activities. This decision is a part of the European Union’s and like-minded partners’ response to Russia’s invasion of Ukraine and the involvement of Belarus in this unprovoked and unjustified aggression.
  • Mastercard and Visa suspended operations in Russia

March 4th

  • The United States Bureau of Industry and Security (BIS) added 91 entries to the Entity List
  • Federal Department of Economic Affairs, Education and Research EAER amended the list of persons, companies, and organizations sanctioned on measures against Myanmar. The change is directly applicable in Switzerland.
  • Russia enacts law punishing spread of “false information” about its “special military operation” in Ukraine, blocking access to Facebook and other news outlets. BBC, New York Times, and others suspend Russian operations in response.
  • Switzerland adopts the EU sanctions on Russia announced on February 28 involving export controls on dual use items; prohibition of exports to Russia’s oil, aviation, and space industries; sanctions on the Russian Central Bank and other financial institutions; removal of Russian banks from SWIFT; and sanctions on numerous Russian individuals.

— Original Post — 3-1-22
Vital4 closely watches all developments in the world of compliance and sanctions. The recent invasion of Ukraine, started by Russia last week, has led to extensive sanctions on Russian businesses and oligarchs. These rapid changes are both expected and atypical in the sanctions world. Though we expect sanctions to take effect quickly and be strict, both the extent of these sanctions and Russia’s position as a major player in global trade make these sanctions particularly unique. To stay abreast of the fast-paced sanctions changes during the current conflict, Vital4 is automatically monitoring primary sanctions hourly to ensure we are capturing the most up-to-date data. Vital4 has also implemented an additional auditing process, to monitor against announced sanctions reports continuously throughout the day.

Our primary mission as a business is to deliver the best, curated datasets for screening and compliance, using Artificial Intelligence and Machine Learning to deliver the most accurate results.  We continue to enhance our systems and practices to make sure our partners always have the best data for their services and products.

United States Sanctions on Russia

On Wednesday, February 24th President Biden, according to the Wall Street Journal, vowed to make Vladimir Putin “an international pariah.” This vow taken and measures taken by the Office of Foreign Assets Control (OFAC) says the new sanctions will target 80% of Russia’s financial assets.

The new measures announced include:

Russia’s two largest financial institutions, Public Joint Stock Company Sberbank of Russia (Sberbank) and VTB Bank Public Joint Stock Company (VTB Bank), will no longer be able to process payments through the US financial system. Sberbank will have correspondent and payable-through account sanctions imposed on it. Blocking sanctions have also been imposed on three Russian financial institutions – Otkritie, Novikom, and Sovcom.

Debt and equity prohibitions against major state-owned and private entities

OFAC has expanded debt and equity restrictions to Russia’s economy. 13 major firms are covered by the directive, including six of Russia’s largest financial institutions.

General licenses 

OFAC has issued multiple general licenses to limit unintended consequences on third parties. The licenses authorize specific transactions related to international organizations, the COVID-19 pandemic, emergency flights, energy, and derivative contracts.

New actions targeting Russian elites

A number of “elites close to Putin” are also being hit with new sanctions. OFAC believes many of these individuals “participate in, or benefit from, the Russian regime’s kleptocracy.”

These individuals include:

Sergei Borisovich Ivanov; Nikolai Platonovich Patrushev; Igor Ivanovich Sechin; Senior executives at state-owned banks, including high-ranking executives at VTB Bank.

 

Canadian Sanctions on Russia

Canada has announced two tranches of sanctions against Russia, including:

  • Financial restrictions on 31 individuals and 27 banks, all connected to Russia’s elite;
  • The halting of all export permits, designed to curb exports worth $750 million across key sectors including aerospace, IT, and mineral shipments

 

United Kingdom Sanctions on Russia

According to Prime minister Boris Johnson, the UK will impose its “largest-ever” set of economic sanctions on Russia. British officials have compiled a “hit list” of oligarchs who will face these sanctions with the full list still to be announced.

So far those confirmed to be facing sanctions include:

Kirill Shamalov; Denis Bortnikov; Yury Slyusar; Gennady Timchenko; Igor Rotenberg; Russian President Vladimir Putin; Foreign Minister Sergeĭ Viktorovich Lavrov

Five Russian banks, including:

Rossiya; The Black Sea Bank; The General Bank; Promsvyazbank; IS Bank

More recently on Monday, February 28th, Chancellor Rishi Sunak announced the UK would join the European Central Bank and Federal Reserve in sanctioning Russia’s central bank.

Sanctions on Belarus:

‘The Foreign Secretary launched the first tranche of sanctions against Belarusian individuals and organizations in response to Belarus’ role in Russia’s invasion of Ukraine.”

Four senior defense officials and 2 military enterprises have been sanctioned with immediate effect under the UK’s Russia sanctions regime.

Those sanctioned include the Belarus Chief of the General Staff and First Deputy Minister of Defense, Major General Victor Gulevich; Major General Andrei Burdyko, Deputy Minister of Defense for Logistics and Chief of Logistics of the Belarusian Armed Forces;

Deputy Minister of Defence for Armament and Chief of Armament of the Belarusian Armed Forces, Major General Sergei Simonenko; Deputy Minister of Defence, Major General Andrey Zhuk.

Also sanctioned are state enterprises JSC 558 Aircraft Repair Plant and JSC Integral, a military semi-conductor manufacturer. JSC 558 provides maintenance and service to military aircraft at Baranovichi airbase, from which Russian aircraft operated as part of the invasion.

Individuals will be unable to travel to the UK and any UK-based assets will be frozen.

 

European Union Sanctions on Russia

Newly implemented EU sanctions are targeting the strategic sectors of the Russian economy by blocking their access to technologies and markets that are key for Russia.

Specific measures announced include:

  • Sanctions against 351 members of the Russian State Duma
  • Sanctions against 27 individuals and entities who have “contributed to the undermining or threatening of the territorial integrity, sovereignty, and independence of Ukraine”
  • Limits on the ability of the Russian state and government to access EU capital and financial markets

The EU has also furthered its sanctions targeting Russia’s financial, energy and transportation sectors including export controls, financing, and visa restrictions, and confirmed it would freeze the assets of President Putin and Foreign Minister Lavrov, widen their sanctions targeting Belarus, ban all Russian aircraft from EU airspace, and authorize measures to target the Russia Today and Sputnik media outlets.


1) How could Russia’s war on Ukraine impact companies in the US?

It seems certain there will be many sanctions and exclusions implemented against Russia quickly. As in the past, with other countries that have received sanctions from the US and NATO, there is a lot of immediate pressure on countries within the alliance to omit Russian entities from their fiscal relationships. Businesses will have an added responsibility to ensure that all sanctions against Russia are swiftly adhered to.

2) How does the increase in post-pandemic fraud attempts impact this situation?

The pandemic and the economic downturn that accompanied it expanded opportunities for bad actors to identify new and strategic methods of committing fraud against entities and individuals. This uptake in fraudulent activity incentivizes government officials to take action to help remedy what has become an enormous issue. As the legislation imposed becomes more strict, the requirements for global businesses to adopt more stringent internal controls to combat fraud and corruption increase. During times of increased conflict, it is especially important to mitigate the risk of fraud, corruption, and terrorism when screening a business or individual up or down the supply chain or before hiring.

3) The economy seems to be getting worse and worse! How will this affect risk?

No doubt, the prices for most essentials have gone up and it does not seem like we are in for relief any time soon! When you couple the current state of the economy with “The Great Resignation”, where 4.3 million workers voluntarily quit their jobs in August of 2021, there is a distinct need to fill all of those abandoned roles. As businesses are desperately trying to rehire their workforce, supply-chain stress coupled with conflict breeds an environment ripe for corruption, fraud, and other abuses. Now more than ever, risk-management task forces and executives need to revisit and evaluate risk mitigation strategies, look for vulnerabilities, and take a clear-eyed view of potential outcomes for the business if the risk turns into reality.