White Paper

Sanctions against Russia

Implementation of the requirements regarding the financial sanctions against Russia in accordance with EU Regulation 2022/263 and 2022/337, and the extended EU sanctions due to Russia’s military invasion in Ukraine. 

This free white paper looks at the individual sanction measures and derives possible safeguards as well as recommendations for action for financial institutions.

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0     Foreword
1     Russia sanctions
1.1  Prohibition of the importation of goods
1.2  Freezing of funds and assets
1.3  Collection/Custody of Deposits
1.4  Providing funding
1.5  Acquisition of real estate
1.6  Assets of the Russian Central Bank
1.7  Sale of securities
1.8  Exclusion from SWIFT
2     Influence on the risk analysis
3     Customer risk classification
4     Summary of the measures
4.1  List processing
4.2  Review of the customer base
4.3  Securities and real estate
4.4  Lending business
4.5  Customer monitoring
4.6  Contract monitoring
4.7  Transaction monitoring
5     Issues not considered
5.1  Cryptocurrencies
5.2  Non-detection of Russia-related transactions
5.3  Belarus

13 Pages

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