Event

Russia Sanctions One Year On: Lessons Learned and What Lies Ahead?

April 5, 2023

FRA and Wilkie Farr & Gallagher co-hosted a conference on Russia sanctions. During the afternoon, leading regulatory, compliance and legal experts came together to explore the impact of the dramatic, sweeping sanctions and export control issued by the UK, US and others in response to Russia’s invasion of Ukraine in February 2022.

With speakers from OFAC, OFSI, and leading in-house practitioners from global financial institutions and companies who have been dealing with the day-to-day impact of compliance with the new and ever-evolving sanctions, the panellists offered an insightful and thought-provoking event.

Key takeaways and photographs from the panel discussions are included below:

Conference Outline

Fireside Chat: Russia Sanctions One Year On: A perspective from Ukraine with Oleksandr Volkov, Counsel at Asters and advisor to the Government of Ukraine
Key Developments in Sanctions Regulation and Enforcement with OFSI and OFAC
Lessons Learned regarding implementing Russian sanctions, ongoing sanctions compliance challenges and takeaways for the year ahead

Key Takeaways

Last year turbo charged an extraordinary package of sanctions. New sectoral sanctions measures were unprecedented in their complexity, timeframe, challenges, involving both the public and private sectors.
Influx of queries and case work meant scaling up in a very short space of time.
Enhanced partnerships through multilateral collaboration intensified hugely since the invasion. Sanctions are certainly most effective when implemented multilaterally.
Since the war, there has been more collaboration between OFAC and the government, with more in-person exchanges going both ways.
levels of cooperation thus far have been unprecedented - although there has been divergence among different regimes, according to scope and geographic jurisdiction.
Collaboration (and its continuation) is crucial in international efforts due to the multinational nature of the sanctions.
Need to make it as clear as possible which entities are owned and controlled in the UK so that sanctions are as hard to circumvent as possible / so that it is simple for those within the industry to follow, improving the rate of compliance.
In the US, sanctions enforcement is more intense, with violations cracked down upon forcefully.
Enforcement agencies struggle with different authorities and finding agreement among many different bodies (different hold ups/red tape within different governments).