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How the EU Enforces Sanctions

How the EU Enforces Sanctions

by Starling Insights

Starling Insights Editorial Board

Apr 23, 2024

Observations

ICYMI: In response to a recent question from the European Parliament, Mairead McGuinness, European Commissioner for Financial Stability, Financial Services, and the Capital Markets Union, explained how the EU has sought to enforce the sanctions regime placed upon Russia following its invasion of Ukraine.

"Since the outset of Russia's war of aggression against Ukraine, the EU has taken a wide range of policy measures to limit Russia's capacity to finance its war of aggression, including through the adoption of 13 sanction packages," McGuinness wrote. "When complying with the framework imposed by the EU sanctions against Russia, banks remain responsible for the selection of their customers and the management of their risks."

McGuinness highlighted the importance of the EU's Operational Risk Framework and the European Central Bank's Supervisory Review and Evaluation Process in this regard. "As part of this framework and process, banks and their competent authorities are expected to assess the legal risk, conduct risk and reputational risk to which banks are exposed due to their activities and to address those risks when they are considered to be excessive," she wrote.

To learn more about the national security implications of financial conduct, read our Compendium interview with Richard Spencer, former Secretary of the US Navy, Owen West, former US Assistant Secretary of Defense for Special Operations, and Timothy O’Neill, a Senior Counselor in Goldman Sachs’ Executive Office.

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