russia-sanctions 06 October 2023

US Treasury: ‘We are not going to let up’ on Russia sanctions evasion

The United States will double-down on efforts to combat circumvention of the sanctions on Russia, a senior US Treasury Department official warned, as she called on financial institutions to adopt policies and systems ‘to understand the underlying controlled goods their clients trade and correspondents facilitate.’

‘One point I want to emphasize about our Russia campaign is that we are not going to let up,’ Treasury’s Assistant Secretary for Terrorist Financing and Financial Crimes Elizabeth Rosenberg told the Association of Certified Anti-Money Laundering Specialists Assembly Conference on 2 October.

‘On the contrary, there are many measures available to us to continue both combatting Russian attempts at circumvention and increasing the pressure generally,’ she said. ‘No one should think that we are anywhere near the end of our energy or creativity on this problem set.’

And she added that the steps will be taken ‘deliberately, seeking to minimize any collateral harm that might occur to our own economic interests, those of our allies, and impacts on the global south.’

Rosenberg explained that ‘as our efforts focus on depriving Russia and its military industrial complex, effective AML/CFT and sanctions policy programs at financial institutions are central to the success of those efforts…

‘It is vital that financial institutions put into place policies and systems to monitor, screen, and analyze trade and customs data to understand the underlying controlled goods their clients trade and correspondents facilitate. Failure to do so, and the continued siloing of AML/CFT and sanctions departments at some financial institutions, can lead to financial institutions unwittingly, or inadvertently, processing payments for controlled goods and involving designated entities. Adopting a proactive approach with regards to this issue will ultimately allow financial institutions to identify Russian sanctions evasion and procurement activities involving sensitive goods that are of interest to the Russian military complex.’