The adoption of unprecedented and innovative trade measures in response to Russia’s full-scale illegal invasion of Ukraine in 2022 has called for a ‘whole-of-society’ response, with sanctions spanning sectors from oil and gas to timber to the manufacture of machine tools. Nonetheless, financial institutions (FIs) remain the main focus of sanctions regulators. The US made its expectations clear in US Executive Order (EO) 14114, issued in December 2023. The Order threatens secondary sanctions against any foreign FI that has ‘conducted or facilitated any significant transaction or transactions, or provided any service, involving Russia’s military-industrial base’. More broadly, joint G7 guidance underscores the critical role FIs play in tackling sanctions circumvention, positioning them ‘on the front line in the fight against illicit finance and Russian sanctions evasion’.
Strengthening the Financial Frontline on Russian Trade Sanctions | Royal United Services Institute
