AML/CFT Sanctions against Russia require businesses to review their existing clientele (B2B and B2B) and identify risks that require an update and/or greater controls in place to manage the wide ranging AML/CFT sanctions imposed upon Russia.
Now is the time for businesses to test operational policies, procedures and controls to ensure compliance with AML/CFT laws. Businesses should be checking underlying business links to Russia territory including asset location, business payments, customer place of birth, customer residency status.
Russia, like Iran and North Korea, will be looking for innovative options to bypass the reach of economic sanctions.
Previously Iran traded gold and leased ships from lower risk countries to move cargo. By flying under a leased ship registered under a low risk country, the red flag may not be so obvious.