Economic sanctions: compliance challenges

Indra Rajaratnam

29.1 INTRODUCTION

The fourth spotlight topic for discussion relates to sanctions compliance challenges posed by sanctions legislation, in the context of credit derivatives trading. Russia’s invasion of Ukraine on February 24, 2022, seen as the largest unprovoked aggression and breach of international law offensive in Europe since World War II, triggered heavy sanctions. These sanctions have been imposed in a ratcheted fashion by democratic nations11 These include the US, EU, UK, Canada, Japan, Singapore and Australia, Singapore, Taiwan and South Korea. through different policy regimes that have been implemented in an unsynchronised fashion, but overall, have largely been unified in their approach. Such sanctions in condemnation of the invasion (the “2022 Russian Sanctions”) are unparalleled. The events in Ukraine have brought home the complexities in managing sanctions compliance risk and executing de-risking strategies within a landscape of international business, where the threat of widening sanctions was increasing daily at the time of writing.

The chapter begins with an introduction to ISDA’s “Sanctions Paper”, which focused on the impact of sanctions legislation on the

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