Ramping Up the Threat of Secondary Sanctions on Foreign Financial Institutions

On December 22, 2023, the Biden administration issued Executive Order 14114. This action increased the scope of items subject to export control restrictions and strengthened U.S. power to sanction foreign financial institutions that facilitate sanctions evasion—both wittingly and unwittingly. Commenting on this action, Deputy Secretary Wally Adeyemo warned the industry, “Stop all transactions from customers selling critical goods or ensure these goods are not benefiting Russia’s war machine. Otherwise, you risk losing access to the U.S. financial system.”

Join Aaron Hutman on May 8 for this webinar presentation, which will focus on the new additions to the Specified Items List, the elimination of the previous knowledge threshold required for enforcement, and due diligence measures necessary to mitigate risk for any commercial activity that may have a nexus to Russia. Panelists will also address the associated OFAC Compliance Advisory, including expectations for reviewing customer activity, risk assessment and use of open-source information on past transaction activity to conduct proactive investigations to identify exposure.

For more information or to register, please visit the event page.