Bloomberg ($) reports that Chinese banks are reviewing Russian exposure, under threat of new US Secondary Sanctions announced last month.

As we have already seen with Iran, when the US introduces secondary sanctions the whole world needs to consider its potential risk exposure. Any of the dozens of institutions who have settled sanctions violations with the US authorities will testify that saying your transaction or even your entire enterprise is not subject to US jurisdiction will not help you.

While the case relates to primary sanctions on Sudan, the settlement between British Arab Commercial Bank and OFAC demonstrates how hard it is to ring-fence yourself from the long arm of US law. 

All businesses must refresh their risk assessments regularly to identify new potential sanctions touch points and the different sanctions authorities to which they may be exposed.

Fairgreen Consulting can assist with risk assessments for businesses concerned about potential exposure.  Please contact us if you would like to have a confidential, free discussion on any concerns you may have.