Key takeaways:

• One of the main factors shaping sanctions compliance trends for 2024 is the increased sanctions pressure on countries recognized as facilitating the circumvention of sanctions.

• This policy leads to stricter compliance requirements for financial organizations, as well as higher compliance thresholds for counterparties from these countries.

• Another important trend is the increase in prosecutions for violations of sanctions and export restrictions.

• One of the goals of increasing the number of prosecutions is to publicize such cases, which forms a compliance culture and demonstrates the policy of government agencies in this area.

   

• The formation in the Russian Federation of a system of countermeasures aimed at blocking property also has an impact on sanctions compliance in 2024, as it makes it necessary to follow clarifications and new draft laws and regulations in this area.

• It also increases the compliance burden on financial organizations monitoring blockchain - they need to build additional controls into their compliance system.

• The legislation also requires financial organizations to document checks on blocked persons for reporting purposes, so interaction with blocked persons will be subject to additional attention from government agencies.