U.S. Sanctions Against Russia Expand to Target Foreign Financial Institutions

The U.S. crackdown on Russia’s purchases of military materials entered a more comprehensive phase in December 2023 with Executive Order 14114 (EO). Under the EO, effective exclusion from the U.S. financial system is now the penalty for financial institutions, in whatever country, that facilitate such transactions or otherwise continue to host accounts for entities and individuals sanctioned for those purchases. Expected to be enforced in a considered, inter-agency manner, the EO will make life harder for third-country institutions hoping to maintain relations both with the U.S. and its global foes. This article explores the EO’s impact with insights from Perkins Coie, Akin and Morgan Lewis. See “Measures Against Russia Pose Serious Compliance Challenges” (Sep. 27, 2023).

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