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Our Response to the Russia-Ukraine Crisis

In order for institutions to navigate these sanctions in a timely manner and protect the integrity of their institution, they may require external support such as the services offered by K2 Integrity. Our sanctions team has served at the highest levels in the U.S. government and draws on deep experience working on sanctions matters at global financial institutions to help clients.

The following areas should be considered in the immediate term to address the impact of these newly imposed sanctions:

Governance and Oversight

  • Strategic advisory support to build, develop, manage, or enhance existing compliance and global sanctions risk management programs, including policies and procedures
  • Test control effectiveness and advise on enhancements, remediation, or development of new controls

Screening

  • Conduct historical transactional reviews to identify and report all required activity or execute targeted risk-based review based on control gaps
  • Conduct sanctions screening model validation resulting in opportunities to calibrate and tune thresholds

Regulatory Reporting and Voluntary Self-Disclosure

  • Support all sanctions- and AML-related regulatory reporting obligations, including responding to any regulatory inquiries
  • Provide voluntary self-disclosure guidance and reporting requirements aligned with OFAC expectations

Managed Services Staffing

  • Augment existing staffing models to provide support during alert surges and increased volumes

Training/Certification 

  • Customized training and certifications for employees at all levels to identify, assess, and manage ongoing and emerging sanctions risks on a global scale
  • Provide tailored training across the enterprise on updated regulatory requirements and any revised internal controls

Investigations

  • Conduct investigations which include identifying and collecting relevant documentary information, interviewing witnesses, analyzing shipping data, and analyzing financial records to trace transactions and the flow of money
  • Develop independent reports of these investigations that can be leveraged by counsel and regulators in connection with self-reporting potential violations

Virtual Asset Advisory Services

  • Advise on strategic compliance and sanction based program and policy updates
  • Provide risk assessments and gap analysis of virtual asset sanctions and BSA compliance frameworks
  • Enhance existing controls to avoid processing sanctioned virtual currency transactions
  • Validate models used for sanctions and AML risk identification in virtual asset transactions

Cybersecurity

  • Sanctions audit
    • Conduct an assessment of an organization’s technology footprint and operations to develop, implement, and oversee appropriate improvements to cybersecurity controls
  • Penetration testing/red team
    • Targeted testing to identify areas of potential weakness that could be exploited by threat actors
  • Ransomware readiness assessment
  • Third-party and supply chain risk management
  • Incident response review
  • Training and awareness campaigns
Key Contacts
On the first anniversary of Russia’s invasion of Ukraine, the United States (U.S.), the European Union (EU), the United Kingdom (UK), the Group of Seven (G7), the Financial Action Task Force (FATF), and other authorities announced a series of sanctions and related actions to inflict additional costs on Russia and further limit its ability to wage war. These announcements demonstrate that both sanctions and strategic trade controls will remain a key tool to counter Russia’s aggression in Ukraine.
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As the Russian invasion of Ukraine continues, so too does Russia’s isolation from the West.[1] Member nations of the Group of Seven (G7)—the United States (U.S.), Canada, France, Germany, Italy, Japan, and the United Kingdom (UK)—and Australia continue to wage an unprecedented multilateral economic pressure campaign that is marked by broad sanctions to punish Russia’s government and restrict its access to global markets, technology, and financial sources, ultimately for purposes of weakening Russia’s ability and will to continue its war of aggression in Ukraine.
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K2 Integrity delivers information and analysis on recent developments related to sanctions against Russia and key implications for the public, private, and non-profit sectors as the United States (U.S.), the European Union (EU), the United Kingdom (UK), and other G7 countries continue to lead a global sanctions campaign that has been unprecedented in its speed, complexity, and impact in responding to Russia’s ongoing war against Ukraine.
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