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ARTICLE · 11 MARCH 2024

How We Can Apply Lessons From War To Exit Endless Whack‑A-Mole Sanctions & Export Controls Compliance

Hughes Hubbard & Reed LLP
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On Friday, February 23, the U.S. announced sanctions and export controls on hundreds of Russian and "enabling" persons and entities to mark the second anniversary of Russia's further invasion...

GlobalInternational Law
Kevin T. Carroll
Kevin T. Carroll
Michael Huneke
Michael Huneke
Sean M. Reilly
Sean M. Reilly
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February 29, 2024 - On Friday, February 23, the U.S. announced sanctions and export controls on hundreds of Russian and "enabling" persons and entities to mark the second anniversary of Russia's further invasion of Ukraine and in protest of the murder of anti-corruption activist Aleksei Navalny. The more than 500 new sanctions "target individuals connected to Navalny's imprisonment as well as Russia's financial sector, defense industrial base, procurement networks and sanctions evaders across multiple continents," while new export restrictions target "nearly 100 entities for providing backdoor support for Russia's war machine."1

All U.S. companies engaged in international commerce, directly or indirectly, are expected to maintain effective compliance programs that screen for, and avoid transactions with, targeted persons and entities. Going forward, the newly sanctioned must be added to the rolls of Know-Your-Customer ("KYC") blacklists maintained by companies and

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