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Financial Services Law Insights and Observations

Treasury official warns that the cost of doing business with Russia is steep

Financial Crimes Of Interest to Non-US Persons OFAC Department of Treasury OFAC Sanctions OFAC Designations Russia

Financial Crimes

On February 21, Deputy Secretary of the Treasury Wally Adeyemo discussed sanctions efforts and export controls taken by a coalition of more than 30 nations over the past year to immobilize the majority of Russia’s sovereign wealth and central bank assets. Adeyemo noted that the breadth of this coalition will enable Russia’s continued isolation, and emphasized that those nations that fail to implement these sanctions and export controls will be forced to choose between their economic ties with the coalition and providing material support to Russia. Recognizing that the Russian government is actively seeking ways to circumvent these sanctions, Adeyemo laid out the coalition’s plan to countering sanctions evasion, as follows: (i) “improve information sharing and coordination among our allies, as well as share additional information with firms in our countries to garner their assistance in preventing countries, companies, and individuals from providing material support to Russia”; (ii) take measures to identify and shut down the specific channels used by Russia to equip and fund its military; and (iii) apply pressure on companies and jurisdictions known to allow or facilitate sanctions evasions. Adeyemo warned that “[o]fficials from the U.S. and the governments of our coalition partners are also engaging with companies and banks in these jurisdictions to tell them directly that if they do not enforce our sanctions and export controls, we will cut them off from access to our markets and financial systems.” He added that the “cost of doing business with Russia in violation of our policies is a steep one, and companies and financial institutions should not wait for their governments to make the decision for them.”