The complexity of imposing sanctions on Russia, and how to overcome the challenges
John E. Kaye

By Dr. Henry Balani, Global Head of Industry and Regulatory Affairs, Encompass Corporation
This week, major Western countries have announced coordinated sanctions against Russia. For example, UK Prime Minister Boris Johnson announced all assets of major Russian banks will have their assets frozen and excluded from the UK financial system – asset freezes on 100 new individuals and businesses. In addition, the US also announced sanctions on billionaires and oligarchs close to President Putin, as well as Russian banks.
Russia is the 11th largest economy in the world, with large companies with multiple subsidiaries, so it is important, here, to recognise the implications of the Office of Foreign Assets Control (OFAC) ‘50% ownership rule’ – that is, any majority owned subsidiary is also automatically sanctioned if the parent company is sanctioned, irrespective of if the subsidiary company is listed on the OFAC list.
What happens now?
Implementing these sanctions could be difficult, as sanctioned Russian companies are aware of this ownership rule and will restructure their subsidiaries to continue to operate.
Therefore, banks will need to review their current clients and understand their ownership structure, while comparing the latest companies and individuals that have been sanctioned. They must, then, validate their subsidiary ownership structure, with the challenge being that these companies will deliberately dilute their subsidiaries to evade sanctions.
Another challenge is that sanctioned banks are owned by billionaires and oligarchs with direct links to President Putin. Banks will have to identify these individuals’ ownership of other companies and, in turn, validate if these companies’ assets need to be frozen.
The implication here is that, if these sanctioned billionaires/oligarchs are majority owners of these companies, it means these companies are in turn sanctioned – the bottom line is that banks must be able to identify these relationships – and quickly.
How to solve these challenges
In the increasingly complex world of Anti-Money Laundering (AML) compliance, identifying Ultimate Beneficial Owners (UBOs) is one of the most important tasks facing compliance teams, and also one of the most difficult. Unwrapping even the simplest of corporate structures to discover beneficial ownership and control is a challenge for banks under normal circumstances, never mind in this kind of situation.
Firms are increasingly turning to RegTech, which offers solutions which can be leveraged to ensure these structures are unwrapped and understood promptly and effectively.
With automation, financial institutions can be sure these critical tasks are being completed, without increasing workload, spend or risk.
The benefits of automated UBO identification and verification solutions for compliance teams include saving time and resources on the complex process of gathering and analysing data from multiple global sources.
Specialised RegTech can also rapidly unwrap ownership and control structures for corporate customers, and automatically examine ownership relationships, calculating shareholding percentages and determining UBOs, in accordance with an organisation’s compliance policies.
TOP STORIES
-
Closing women's health gap could boost global economy by $1tn a year, leaders say -
World's first luxury theme park to open in Mexico with £1.1bn of rides, fine entertainment and deliberately limited crowds -
Dutch court orders Lidl to stop selling Birkenstock sandal lookalikes -
Giant wind turbine with 252-metre rotor could mean fewer machines and cheaper offshore power -
Poorly designed workplaces ‘cost UK economy £71bn a year’ -
Rescuers scramble to protect pod of 25 whales in Thames Estuary -
‘Talent hushing’ blamed as four-in-10 workers say they contribute less than they could -
Spain leads Europe for expats as Panama tops global poll -
Menopause may make women leaders more empathetic – even as it leaves them drained -
Your biggest rival could be your best technology partner, research finds -
British Museum bans photos of Bayeux Tapestry after visitors hold up queues -
China unveils giant crane capable of lifting 9,300 family cars -
Edinburgh Airport launches £500m expansion as terminal footprint grows 60% -
Chris Packham urges PM to ban ‘frankenchicken’ from schools and hospitals -
Loch Lomond’s 'Bonnie Banks at risk’ from major road upgrade -
LED lights could be ‘the new asbestos’, UCL scientists warn -
MPs tune in to Britain’s Eurovision ‘nul points’ problem -
MPs tell Government to reject Thames Water creditors as utility nears insolvency -
Only 14% of companies can show supply chain safeguards are working, study finds -
OpenAI admits AI models hid mistakes, invented data and acted without permission -
EIB makes first small nuclear reactor investment with €40m backing for Finnish start-up -
AI arms race could mean fewer cold emails reaching your inbox -
Housing costs hit recruitment at 77% of large London firms, survey finds -
SpaceX to launch one-tonne orbital factory for European space firm in 2028 -
Estonia’s e-residents launch more than 4,200 companies as business creation jumps 36%




























