Does Your Sanctions Compliance Program Cover Your Exposure to Russia Sanctions?
The massive scale of global sanctions against Russia, which has surged dramatically since 2022, has changed sanctions compliance forever. This has exposed businesses in Europe and particularly in countries like the G7 group to an unprecedented risk of circumventing Russian sanctions. For compliance professionals, understanding this 'new normal' is not just crucial—it's foundational to survival and strategic growth.
This AML Watcher analysis, built on its screening database, moves beyond a mere snapshot, offering critical insights and actionable intelligence to empower your organization to navigate its risk exposure to Russian Sanctions.
We'll dissect the unprecedented financial sanctions, the heightened threat of secondary sanctions risks, the evolving target types of sanctions, and the significant impact on global trade and sovereign assets.
The above map visualizes an extensive scale of blocs or countries that have participated in or imposed financial sanctions or trade restrictions against Russia.
Financial Sanctions on Russia
The financial arsenal unleashed against Moscow is vast. But which nations are leading the charge, and what does this concentration of Russia sanctions mean for the AML compliance program of financial institutions?
The above chart lists countries or blocs leading the charge on sanctions against Russia, along with key areas (companies, vessels, and individuals) targeted by them. This not only highlights the broad cooperation between significant economic powers but also the increased demand for sanctions compliance to prevent potential fines for non-compliance.
For example, a company operating in the shipping industry of Ukraine, the UK, the EU, or the US will be highly exposed to sanctioned Russian vessels/ships.
Similarly, businesses in the US, the EU, the UK, Canada, Australia, and Japan face a heightened risk of dealing with a designated individual or legal entity.
Surge in Russian Sanctions: 2022 vs. 2025 Comparison
Though Russia has been the target of financial sanctions since 2014, after it annexed Crimea, the scale of sanctions imposed after its invasion of Ukraine in 2022 is unlike anything in the past, especially with new countries like Estonia, Japan, New Zealand, Norway, Singapore and South Korea joining the wave for the first time. Businesses in these countries may need to update their existing compliance programs to adapt to the changing sanctions landscape.
As AML Watcher data reveals, the increase in the number of sanctions against Russia from 2022 (since the start of the Russia-Ukraine war) to the present (until May 2025) is staggering. The volume of sanctions against Russia has increased by more than 8 times. This rapid expansion calls our attention to the dynamic nature of the sanctions landscape and the need for continuous monitoring.
OFAC Secondary Sanctions Risks
Secondary sanctions target entities that do business with sanctioned parties, even if they are not directly involved in the initial sanctionable activity. Among all the sanctions programs implemented by the United States, those against Russia pose the highest risk of secondary sanctions. This can significantly impact:
- Global trade and supply chains
- Financial institutions with international operations
- Companies that maintain business relationships with Russian entities
AML Watcher Expert Take:Â
“OFAC’s extensive secondary sanctions against Russia are more than a regulatory hurdle. It’s reshaping global sanctions compliance. The clear message is that even non-US firms risk being directly sanctioned by the OFAC if their business network connects to sanctioned Russian entities. This reality demands a clearly secondary sanctions-labeled database and proactive network intelligent risk assessment."
Russian Sanctions by Target Type
Who is the target of sanctions against Russia? Countries imposing sanctions on Russia designate diverse types of entities in their lists. An analysis of those sanction lists indicates that the highest number of targets are individuals, followed by a significant number of Russian organizations, and then Russian vessels and aircraft. This widespread targeting creates compliance challenges, supply chain disruptions, restrictions on financial transactions, and increased operational risks for global businesses.
Key Sectors Impacted by Trade Restrictions on Russia
Many countries and regional blocs have also imposed extensive trade restrictions on Russia. These restrictions target key Russian exports such as crude oil, coal, natural gas, gold, diamonds, luxury goods, and seafood etc. Whereas the Russian imports targeted by these restrictions mostly include military & dual-use items, semiconductors, AI, energy sector, software technology, and luxury goods.
Frozen Sovereign Russian Funds
Coordinated financial sanctions have immobilized an estimated $280-$300 billion of the Russian Central Bank's foreign exchange reserves held in sanctioning jurisdictions. Approximately €210 billion is in EU member states, with €183 billion at Euroclear in Belgium. Other significant amounts are directly held in the United States, France, Switzerland, and the United Kingdom. Whereas Japan, Canada, and Australia also have a considerable share via Euroclear.
The immobilization of Russian sovereign assets, with the EU holding the lion's share, is not just a punitive measure. It represents a significant pool of funds that could be subject to future legal battles, reparations claims, or even leveraged in negotiations, creating ongoing uncertainty and potential compliance ripples.
Upgrade Sanctions Compliance Program Proportionate to Your Risk of Russia Sanctions
AML Watcher Recommends:
Enhanced Due Diligence (EDD):
- Firms in key sanctioning jurisdictions (e.g., the US, EU, and UK) must review sanctions compliance programs.
- Update policies: Include Enhanced Due Diligence for all individuals, entities, or vessels with potential Russia links.
- EDD must clarify beneficial ownership, ties to Russian state-owned enterprises, and geographic risk.
Supply Chain Auditing:
- Businesses in countries with extensive Russian trade restrictions (e.g., the US, EU, Japan) must audit their supply chains.
- Identify all links to restricted Russian companies, goods, or sectors.
- Beware of evasion: Re-routing restricted goods via trade hubs is a common tactic.
- Map supply chain dependencies. Secure alternative sources to prevent disruptions and avoid dealing with restricted parties.
Technology & Analytics:
- Use advanced screening tools customizable to your specific business risk exposure.
- Combine comprehensive sanction/PEP data with adverse media screening to uncover hidden links with designated entities.
- Basic list screening is no longer enough, especially due to regulations like the OFAC 50% Rule, which targets unlisted entities.
Continuous Monitoring & Training:
- The Russia sanctions landscape evolves rapidly.
- Continuously monitor regulatory updates and new evasion techniques.
- Ensure your compliance team receives regular, advanced training on these changes.
How Do AML Watcher’s Solutions Empower Businesses to Overcome Challenges in Sanctions Compliance?
The global response to Russia's actions has launched a new era of complex and rapidly evolving sanctions. Many jurisdictions, numerous designations, and wide-ranging targets now create intense compliance challenges for businesses everywhere.
AML Watcher champions a proactive, risk-based compliance approach. Its AML solution is equipped with comprehensive sanctions data, clearly labeled for contexts like secondary sanctions risk, along with ongoing monitoring. Its data updates every 15 minutes helping businesses build operational resilience globally.
Sanctions are now a primary tool of international policy. Maintaining rigorous compliance is therefore critical. Success in this environment depends on advanced data, expert analysis, and collaborative intelligence—all key to lasting business resilience and integrity in the global marketplace.
AML Watcher is Open to Leverage its Screening Solutions and Data for Research Collaborations in the AML and Sanctions Field
"AML Watcher is committed to advancing the global understanding of AML and sanctions compliance, a venture fueled by the data and expertise from our cutting-edge AML and Sanctions Screening solution. We invite journalists, academic researchers, and intelligence analysis firms to explore research partnerships, leveraging the rich, anonymized data from our proprietary AML Watcher Database – the same robust data that powers our compliance solutions for clients worldwide. Together, we can uncover new insights, enhance public awareness, and strengthen global compliance frameworks. Contact us to discuss how our data can support your research."
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