U.S. Deputy Attorney General Lisa Monaco has called sanctions “the new FCPA.” In the coming months and years, global sanctions enforcement regimes will sharpen their focus on sanctions compliance programs of financial institutions — and the identification of sanctions risk in particular — as the Russian sanctions raise the stakes for accountability among institutions to preempt prohibited activity. Institutions should recognize this shifting dynamic and plan for convergence in enforcement activity.   

This whitepaper highlights the advances in sanctions enforcement in the U.S., the EU and the U.K. and explains how finance firms can reposition themselves accordingly.