A Growing Concern: Complying with Russian Sanctions 6 Months Later

In the six months since Russia’s invasion of Ukraine, countries across the world have stepped in with sanctions to attempt to damage Russia’s economy and weaken their military power.

For sanctions to be effective, enforcement and compliance teams need to be on top of things. The challenge with this series of sanctions is that over the past six months it’s been nonstop. As the Russia sanctions environment continues to evolve, it’s increasingly difficult for businesses who operate in the U.S. to stay up-to-date with the hundreds – and seemingly endless – new sanctions list updates.

U.S. Doubles Down on Threats Against Russia

Even as recently as the first week of August, the Treasury and State departments have continued to impose new sanctions. The latest sanctions included visa restrictions, sanctions on multinational companies and designations for oligarchs and entities involved in finance, technology and scientific research.

The United States has issued far-ranging sanctions on Russia in a number of industries, including, but not limited to, the following: 

  • Banned the import of Russian crude oil, petroleum products, liquefied natural gas, coal, gold, diamonds, seafood, and alcoholic beverages
  • Suspended normal trade relations with Russia and Belarus and increased tariffs on otherwise permissible imports from those countries
  • Added hundreds of Russian individuals, including Putin, Lavrov, Security Council members, politicians, government officials and ministers, oligarchs, business executives, and their family members to the Specially Designated Nationals and Blocked Persons List, which prohibits Americans from engaging in any transactions with them 
  • Imposed blocking sanctions on Russia’s largest banks, including Sberbank, VTB Bank, VEB, Alfa Bank, the Russian Direct Investment Fund, the Central Bank of Russia, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation
  • Imposed restrictions on over 2,000 Russian businesses including notable entities such as Rostec, Alrosa, Severstal, United Shipbuilding Corporation, Nord Stream 2 AG, and several aerospace, marine, electronics, defense, and virtual currency mining companies
  • Prohibited Russian aircrafts from entering U.S. airspace and Russian vessels from entering U.S. ports
  • Prohibited most transactions and activities with individuals and entities in the Russian-occupied Donetsk, Luhansk, and Crimea regions of Ukraine

This list is far from exhaustive. The Department of the Treasury maintains a complete list of sanctions on their website. We maintain a number of sanctions lists in Sayari Graph from a range of sources including, OFAC, HMT, the EU, and the UN, among others.

A Global Effort

The United States isn’t in this fight alone. Over 30 countries have issued their own sanctions on Russia, including the European Union, Japan, Australia, Canada, the United Kingdom, and South Korea. While global efforts can increase the impact that sanctions have on Russia, it can complicate things even further for financial institutions and commercial enterprises that operate across different countries. 

Not all sanctions are created equal. Each country has their own list of sanctioned business activities and entities, although EU nations tend to operate under similar sanctions guidance. 

The Peterson Institute for International Economics, an independent nonprofit, nonpartisan research organization, compiled a complete timeline list of worldwide sanctions against Russia, tracked since November 2021. This list is a great starting point for compliance officers looking to stay up-to-date on sanctions updates around the world.

Effective Sanctions Compliance

The reality is, the flood of sanctions, export controls, and prohibitions against Russian entities have posed major challenges for global banks and businesses. Carefully consulting the lists upon lists of sanctions regulations is just the first step to mitigating the associated legal, commercial, and reputational risks of not complying.

You can’t cut ties with sanctioned Russian or other high risk entities if you don’t know those links are there. Banks and businesses have already needed to audit their clients and vendors against these lists. But as the war in Ukraine continues and sanctions lists change, this will increasingly be a challenge.  

Effectiveness will be key to sanctions compliance. You may not have deep insight into risk-related entities beyond your direct customers or vendors. But understanding these broader relationships is crucial to effectively mitigate risk that may remain hidden.

Sayari Graph leverages global public records and graph technology to map complex, cross-border corporate networks, thus providing a clear picture of illicit financial actors, their infrastructure, and relationships. This comprehensive view provides investigators with broader context surrounding their customers and counterparties – a key aspect for effective sanctions compliance. 

The data within Sayari Graph is updated regularly to ensure that you’re always working with the most current information. The platform’s Risk Factors feature can also visually flag any known Russian entity that has appeared on any sanctions list throughout an investigation. 

Speed up your compliance investigations with Sayari Graph. See the impact for yourself with a 14 day free trial of Sayari Graph. For inspiration, watch one of our in-house analysts perform an example investigation in this Master Class on tracking assets of Russian oligarchs

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