This article originally appeared in the March/April 2023 issue of ABA Bank Compliance.
Approximately one year ago, in the immediate wake of Russia’s full-scale invasion of Ukraine, the United States (U.S.), United Kingdom (UK), and European Union (EU) launched a global sanctions campaign against Russia that quickly became unprecedented in its speed, complexity, and global impact.
As we now look back at the evolution of the global sanctions campaign against Russian aggression throughout 2022, both the impact and trajectory of this campaign have become clearer with important consequences for financial institutions’ (FIs) risk management programs.
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