New Sanctions Against Russia and Belarus Effective June 7, 2022

On May 8, 2022, the United States, through the Office of Foreign Assets Control (OFAC), introduced new sanctions against Russia and Belarus. The new sanctions will take effect on June 7, 2022, and will prohibit any accounting, entity formation, or consulting services to any Russian or Belarusian person or entity. 

Companies should:

1. Assess core system updates to include areas such as, but not limited to, Automated Clearing House (ACH) transactions and files, wires processing systems, and onboarding systems;
2. Consider vendor management risk and review compliance with the sanctions; and
3. Review screening for new accounts, investors, loans, and other third-party offerings.

Organizations also should review existing and future (potential) relationships. Sample questions might include:

• Do any of your investors, related parties or vendors have a connection to Russia or Belarus?
• Are any of your investors or related parties 50% or more controlled by a Russian or Belarusian person or entity (likely identified through beneficial ownership)?
• Are any of your investors owned by offshore holding entities based in tax haven countries?
• Will your investors or related parties engage in any transactions related to Russia or Belarus?
• Do any of the related parties or investors have Russian or Belarusian citizenship?

If you are unsure if you or your company are affected by the new sanctions, it is recommended that you seek immediate legal counsel. Better to be safe than sorry!

Thanks to Karen Leiter for her assistance with this blog post.