Publication | BRG

Emerging Risks: Mitigating Sanctions and Reputational Exposure

Michael Pace, Steve Klemencic, and Kelli Foy

March 2022

In response to Russia’s invasion of Ukraine, numerous countries and governing bodies, including the United States, United Kingdom, and European Union, have imposed coordinated economic sanctions on Russian banks, organizations, oligarchs, and other high-profile individuals. The US, UK, and EU also have adopted export restrictions on various categories of goods and technology, including those that may contribute to Russia’s military efforts or technological advancement.

In addition to sanctions and export controls, seven Russian banks have been removed from the Society for Worldwide Interbank Financial Telecommunication (SWIFT) messaging system. The SWIFT system facilitates international transactions in over two hundred countries. Iran and North Korea are the only other countries that have had their institutions disconnected from SWIFT.

As Russia’s invasion has escalated, the expanding sanctions regimes and export controls have evolved and become more complex, with updates coming almost daily. With each new update, companies must continue to evaluate the risks of doing business in the region, which requires a thorough analysis of the law.

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Steven Klemencic

Managing Director

Washington, DC