U.S. actions to Russia-Ukraine war: Expanded regulatory attentions

Financial services companies are facing rapid and iterative OFAC sanctions and Administration executive orders. Regulators will expect companies to comply with the new requirements as well as monitor and mitigate compliance risks directly and via counterparties, third parties, etc. In addition, regulators are signaling expanded attention to financial crimes, cyber security, and crypto and digital assets. Regulatory expectations in these areas are evolving though all are tied to the Administration’s whole-of-government national security initiatives and as such are already subject to heightened attention. Notably, both Treasury and the Federal Reserve Board have denoted increased attention to crypto and digital assets.