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ARTICLE · 13 SEPTEMBER 2022

Finance | Q3 2022

Schoenherr (Schönherr Rechtsanwälte)
Schoenherr (Schönherr Rechtsanwälte)
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Schoenherr (Schönherr Rechtsanwälte)

Schoenherr (Schönherr Rechtsanwälte)

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Sanctions compliance and related process and systems updates have kept compliance, legal and IT teams in financial services providers busy since March 2022.

AustriaFinance and Banking
Schoenherr Attorneys At Law
Schoenherr Attorneys At Law
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Money rules | EU

  • Sanctions compliance and related process and systems updates have kept compliance, legal and IT teams in financial services providers busy since March 2022. There has been a huge effort to ensure compliance with a plethora of rapidly enacted (financial) sanctions, including around deposit-taking and securities services as well as crypto assets. Moreover, payment instructions from customers often have to be closely scrutinised as to compliance of the underlying transaction, e.g. supply or purchase order. Frequently, these tasks coincided with the involvement of sanctions experts in (attempted) asset swaps concerning Russia-related exposures.

Now, as Q3 draws to a close, I am reminded of the popular proverb that you can't make an omelette without breaking eggs. Despite herculean efforts, not every system or process that had to be implemented literally overnight worked out perfectly from the get-go. And this appears to have attracted the

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AustriaFinance and Banking
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