1 00118601 Emerging themes 2019 A4 AW v31 combined - Page 69



EMERGING THEMES 2019
A DELICATE
BALANCE
HOW SHOULD WE APPROACH
COMPETING SANCTIONS RISKS?
Among the numerous regulatory compliance risks faced by
financial institutions, economic and trade sanctions risks
commonly receive a great deal of attention. The imposition
(and re-imposition) of additional secondary sanctions by the
US, together with the number of high-profile US enforcement
matters involving financial institutions, only adds to the risks
that financial institutions must consider when evaluating their
sanctions compliance strategy. Non-US financial institutions are
not immune from such risks. Yet they must consider these risks in
the context of local legal requirements that impact sanctions
compliance, including the EU Blocking Regulation.
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