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Compliance Hot Spots: MoFo Lawyers on Managing Risk in Russia Sanctions Crisis

Law.com

23 Mar 2022

John Smith and Brandon Van Grack spoke to Law.com about the unprecedented economic response from Western governments following Russia’s war on Ukraine, which has sent companies scrambling for legal counsel on how to comply with new restrictions, prepare for the Justice Department’s (DOJ) coming enforcement crackdown, and manage reputational risks as the backlash grows.

“This is going to be and already is a primary focus” for the DOJ, Brandon said about the KleptoCapture Task Force. “Sanctions and export controls are some of the primary national security tools and leverage that the U.S. government has. But ultimately, those sanctions, those controls only work if they’re enforced. And so I think what you’ve seen by not just the announcement of the task force, but some of the investigations and charges that they’ve announced, is that this is their national security priority. They are marshaling resources, they are going to and already are enforcing these aggressively. And so I don’t think this is just a label. You’re going to see and are already seeing a substantial pivot, and I think in the coming weeks and months you’re going to see a lot of different actions along those lines.”

About the Office of Foreign Assets Control (OFAC), John added: “They’re superstars. They shattered the playbook from what the previous sanctions rule escalation plan would be. They’re obviously working around the clock, keeping the pace of new sanctions, new developments, adding new names on the list. They’re providing additional guidance to answer public questions, as well as new policies to enhance the sanctions, along with a significant level of coordination. The most striking thing about these sanctions is not what any one government is doing, including the United States, but it’s the fact that they have such a consensus that they’re getting governments around the world to join in.”

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