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Financial Services Law Insights and Observations

Treasury says foreign financial institutions risk sanctions if they provide material support to Russia

Financial Crimes Of Interest to Non-US Persons Department of Treasury Illicit Finance Russia Ukraine Ukraine Invasion OFAC Sanctions

Financial Crimes

On May 13, Deputy Secretary of the Treasury Wally Adeyemo warned representatives from several foreign financial institutions about the risks of aiding Russia in evading sanctions imposed by the U.S. and its allies following the country’s invasion of Ukraine. Adeyemo emphasized that institutions may face “sanctions exposure for providing material support to a sanctioned entity,” and stressed that the U.S. Treasury Department’s Office of Foreign Assets Control “expects all financial institutions to do their own due diligence to ensure they are not transacting with a sanctioned person.”