Key takeaways:
In 2024, sanctions pressure on "third countries" is expected to continue in order to counteract the circumvention of sanctions through "third" jurisdictions. In 2023, such trends have emerged in the USA and EU.
An important trend in 2024 is the countries' focus on prosecution for violations of sanctions restrictions and on export controls. The USA, EU and UK have already launched work in this direction.
Another change expected in the area of sanctions in 2024 is the development of asset confiscation mechanisms. Both sovereign assets and assets of individuals are being considered for confiscation.
The described trends will lead to more complicated interaction with counterparties and banks in "third countries", to difficulties in the flow of payments and settlements (freezing and suspension of payments), to the dependence of compliance trends on prosecution cases, and to the emergence of confiscation risks of assets abroad, that may lead to retaliatory measures of the Russian Federation.