Sanctions against Russia has been a topic of increasing importance since the illegal annexation of Crimea in 2014, but the sanctions rapidly imposed by the EU, US and UK since end of February exceeds anything we have seen before in numbers and content, as well as coordination between sanctions authorities. With some exceptions EU’ sanctions up to and including the 5th sanctions package have so far been implemented in Norway, making them directly applicable to us. The sixth package will be implemented in Norway shortly .
Complex ownership structures are challenging
Due to the situation in the Ukraine, Eksfin is closed for new transactions in Russia and Belarus. Ukraine is put on hold. The main challenge going forward will be to avoid breaching sanctions against Russia when doing business abroad.
With more than a thousand Russian individuals sanctioned, and calculation of aggregate ownership of sanctioned individuals, there is a massive number of companies around the world that could be sanctioned by extension. With the rapid update of sanctions and listing of new individuals and entities this is not a one-time task, but a continuous process.
For Eksfin, and Norwegian businesses in general, it is essential to have adequate procedures in place to carry out thorough Know Your Customer (KYC) checks on complex ownership structures. You really need to know who you are doing business with.
Anita Gerdin, Lawyer and Senior Compliance Officer at Eksfin