Within a week of Russia's invasion of Ukraine, businesses around the world abandoned ties with Russia to comply with some of the toughest and most coordinated sanctions to date. The speed at which sanctions were imposed left many questions unanswered, resulting in a flurry of calls and messages to attorneys who themselves were trying to understand the ramifications. As with all rapidly changing situations, each business and its dealings are multi-layered and therefore the answers aren't always straightforward.

Enhanced Due Diligence

It is advisable for all U.S. businesses and legal counsel to educate themselves on the latest sanctions and impose additional protocols for ensuring compliance. The U.S. Department of Treasury website includes an up-to-date resource center to serve as a starting point, but compliance teams should conduct an assessment of their current relationships. Sanctions particularly block Russian individuals and businesses from interacting with the U.S. financial system, including prohibiting transactions.