Article
The EU’s 20th And 21st Russia Sanctions Packages: A New Compliance Architecture For Financial Services Firms
The European Union's 20th and 21st sanctions packages against Russia mark a fundamental shift in enforcement strategy, moving beyond traditional designation lists to systematically target the financial infrastructure enabling Russia's war economy. Financial institutions now face heightened compliance obligations requiring them to identify how transactions, financing arrangements, and digital assets may indirectly facilitate sanctioned economic activity across payment channels, banking relationships, crypto-
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