Sanctions start high and stay high
2022 Year in Review
Economic Sanctions and AML Developments
What’s in this report from Paul, Weiss:
A central theme of the global financial landscape in 2022 was the U.S. government’s sanctions, AML and export control authorities’ forceful response to Russia’s invasion of Ukraine. Following a “start high/stay high” strategy, the Biden Administration imposed sanctions targeting prominent Russian financial institutions, state-owned entities, government agencies and officials and oligarchs with unprecedented speed, breadth and coordination with allied countries (including the United Kingdom, members of the European Union, Japan, Canada and Australia).
A team from Paul, Weiss dissects these moves, as well as other policies by the Biden Administration. Here are some highlights of their analysis:
- Russia, “a quasi-comprehensively sanctioned jurisdiction.” Leading the report and dominating a year of broad-based national and international regulatory action is the U.S. government’s deployment of far-reaching sanctions that “have increasingly made Russia effectively a quasi-comprehensively sanctioned jurisdiction.
- A wide sweep of rulemaking and sixfold increase in penalties and seizures. The report also surveys sanctions and export controls against China; placement of the Nicaraguan state-owned gold company ENIMINAS on the SDN list; some loosening of sanctions against Venezuela; and the placement of two cryptocurrency mixers on the SDN list. It overviews multi-agency actions that resulted in federal and state authorities imposing nearly $4 billion in penalties and asset seizures for AML/sanctions violations – nearly a sixfold increase over 2021.
