U.S. Actions to Russia-Ukraine conflict

The United States and other countries have imposed new sanctions and/or export controls on Russia, Belarus, and certain regions of Ukraine. Companies face heightened risk associated with sanctions compliance as well as the management of their correspondent banking relationships. Companies should quickly:

• Assess company activities to determine whether authorizations are now required for sales, support, procurement, or other activities.
• Update or perform dynamic risk assessments given evolving events and trade restrictions.
• Ensure that restricted party screening is updated with the most recent government lists.
• Develop and implement a plan for complying with the U.S. and EU “50 Percent Rules” if not already in place.
• Update screening filters to identify records mentioning locations in the “so-called Donetsk People’s Republic (DNR) or Luhansk People’s Republic (LNR)” regions of Ukraine to ensure such locations generate an alert for human review.

Of note, the U.S. Cybersecurity and Infrastructure Security Agency has urged all organizations to strengthen their cyber security due to increased potential threats. Companies in financial services and critical infrastructure should be vigilant to potential threats, take precautions as feasible and immediately notify the appropriate escalation channels in the event a cyber incident is detected.