Global geopolitical transformations always create new risks for the financial system. The burden of promptly responding to these changes traditionally falls on banks since legislative regulation is always delayed due to bureaucracy. As a result, and without formal guidance, US banks must independently assess new compliance risks and develop an action plan.
Due to Russia’s actions in Ukraine, global markets are experiencing a ‘perfect storm’ of sanctions. At the same time, we have to understand that sanctions policy is a chess game. After each new US sanction, Russia makes a retaliatory move.