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Russia Sanctions: Meeting the Compliance Challenge

 

Our panel of legal, regulatory, and compliance experts discussed the compliance challenges presented by increasing Russian sanctions.

Navigating the complex web of hidden, informal relationships that characterize the Russian business scene has long imposed a heavy burden on compliance professionals. The reliance of many large Russian businesses on obscure intermediaries that can siphon funds offshore, for example, demands special records research competencies and, often, multiple language skills to uncover middleman arrangements that may divert funds offshore or mask sanctions evasion schemes. 

The dizzying speed and breadth of the most recent rounds of Russia-related sanctions has even the most Russia-savvy C-suite and risk professionals concerned about whether the screening, investigative, and diligence processes that are in place are now sufficient to meet expectations (at a time when there are clear signs that regulatory enforcement is growing).  

As international outrage about Russia’s atrocities in Ukraine accelerates and sanctions expand, we assembled a panel of legal, regulatory, and compliance experts to highlight screening, investigative, and due diligence best practices.

 

 

The Expert Panelists:
3-1 Thomas Firestone (1) Duncan Nott (1)

Mihnea Rotariu
Risk and Compliance Analytics Director | Lextegrity

Thomas Firestone
Partner | Stroock &
Stroock & Lavan

Duncan Nott
Senior Vice President | Integrity Risk International

Mihnea Rotariu has an extensive background in handling matters involving bribery and corruption, forensic accounting, monitorships, regulatory compliance, data analytics, and due diligence from his time at PwC and FRA. He has previously assisted counsel in enforcement matters brought by the U.S. Department of Justice, the U.S. Securities and Exchange Commission, and international enforcement agencies. 

Mihnea holds several certifications, including Fellow of the Association of Chartered Certified Accountants (FCCA), Certified Fraud Examiner (CFE), and Certified Anti-Money Laundering Specialist (CAMS).

Thomas Firestone is a partner at Stroock & Stroock & Lavan, where he specializes in international criminal and compliance matters related to FCPA/anti-corruption, sanctions, money laundering, FARA, Interpol, human rights, and the rule of law. Prior to joining Stroock & Stroock & Lavan, he spent 14 years with the U.S. Department of Justice. While there, he served as a federal prosecutor in the Eastern District of New York specializing in international organized crime and as the Resident Legal Advisor at the U.S. Embassy in Moscow with a focus on U.S.-Russian law enforcement cooperation. 

Thomas is a two-time recipient of the State Department Superior Honor Award and has represented clients in some of the most significant criminal cases in Eastern Europe.

Duncan Nott is a senior executive with Integrity Risk International with a global track record leading integrated risk management programs within a diverse range of industry sectors. Prior to joining Integrity Risk International, Duncan served as Global Head of Security for UBS AG for 14 years. During his tenure, he managed multiple high-profile EDD projects and led several corporate investigations and major operational risk events. 

Duncan has been working with multinational organizations to manage operational risk, crisis management, investigations, and EDD for three decades.