Compliance Clarified – a podcast by Thomson Reuters Regulatory Intelligence
Season 4, Episode 10: Sanctions – intended and unintended consequences and how to deal with them
Apr 5, 2022
Susannah Hammond, an expert in compliance and sanctions, is joined by Rachel Wolcott and Brett Wolf to discuss the current state of play with sanctions and the unintended consequences arising from the response to the conflict in Ukraine. They explore challenges faced by financial institutions, personal liability for UK firms, the use of Swift as a sanctioning weapon, unintended consequences of sanctions, and the importance of documentation in dealing with sanctions.
39:07
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Quick takeaways
- Compliance officers are reevaluating their sanctions programs and considering cautionary self-sanctioning.
- Firms in the UK and EU face challenges in navigating different sanctions regimes and may discover weaknesses in their systems and controls as they assess compliance.
Deep dives
Implications of US sanctions on Russia
The United States, along with the UK, EU, and other allies, has imposed multiple sanctions on the Russian government, businesses, officials, and wealthy elite since Russia's invasion of Ukraine. Compliance officers are reevaluating their sanctions programs and considering cautionary self-sanctioning. Financial institutions are conducting enterprise-wide reviews of client relationships, assets, transactions, and counter parties linked to the payments being processed, which involves checking against complex corporate structures and associated individuals tied to the parties that have been sanctioned.
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