New Risks to Non-US Financial and Other Institutions Engaging in Transactions with US and EU Sanctioned Entities

    View Authors October 2014

    Non-US financial and other institutions that engage in transactions with sanctioned businesses, persons and countries expose themselves to increased risk of violating US and EU sanctions. For years, the US has imposed comprehensive sanctions against Cuba, Iran, and Sudan, as well as designated organizations and individuals. A new sanctions regime against Russia not only prohibits US and EU persons and entities from certain dealings with sanctioned Russian businesses, but also creates risks for non-US financial institutions and other entities if they are alleged to have “caused” US persons and entities to violate the sanctions, for example, by facilitating transactions that are alleged to evade the sanctions.