On December 22, 2023, the Biden administration issued Executive Order 14114. This action increased the scope of items subject to export control restrictions and strengthened U.S. power to sanction foreign financial institutions that facilitate sanctions evasion — both wittingly and unwittingly. Commenting on this action, Deputy Secretary Wally Adeyemo warned industry: “Stop all transactions from customers selling critical goods or ensure these goods are not benefiting Russia’s war machine. Otherwise, you risk losing access to the U.S. financial system.”

This discussion will focus on the new additions to the Specified Items List, the elimination of the previous knowledge threshold required for enforcement, and due diligence measures necessary to mitigate risk for any commercial activity that may have a nexus to Russia. Panelists will also address the associated OFAC Compliance Advisory, to include expectations on reviewing customer activity, risk assessment and use of open-source information on past transaction activity to conduct proactive investigations to identify exposure.

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Panelists:

Aaron Hutman, Partner, Pillsbury Winthrop Shaw Pittman LLP

Aaron Hutman is a partner in the Washington, D.C. office of Pillsbury Winthrop Shaw Pittman LLP. Aaron helps clients to engage in business, banking and trade in the world’s most challenging markets and deal with the most sensitive technologies.

With experience in over 60 countries on six continents, Aaron understands the bigger picture issues of international business and is an established authority in some of the most important issues affecting trade, banking and investment, where companies and investors face a business landscape with ever-evolving sanctions, anti-money laundering, anticorruption, cybersecurity, trade disputes and investment rules that must be understood, anticipated and managed. His clients include defense companies, private equity and hedge funds, banks, multinational corporations, energy industry participants, social media and technology leaders, startups and governments around the world.

Marios Skandalis, Chief Compliance Officer, Bank of Cyprus

Marios Skandalis is a senior financial sector executive with extensive experience both in the local as well as international markets and today is the Chief Compliance Officer of the Bank of Cyprus Group. He is a Fellow member of the Association of Chartered Certified Accountants (UK), a licensed member of the Association of Certified Fraud Examiners (USA) and a Fellow member of the Chartered Governance Institute – ICSA (UK). He is also a Fellow member of the International Compliance Association (UK) and a professional member of the Society of Corporate Compliance and Ethics (USA).

Marios is the President of the Cyprus Integrity Forum (CIF), the largest non-governmental organization in Cyprus for combatting corruption and promoting transparency, as well as the founder member and Honorary President of the Cyprus Compliance Association (CCA). He is also a Board member of the Global Practitioner Advisory Board of the International Compliance Association (ICA – UK).

He is an active anti-fraud/corruption, compliance and corporate governance professional and chairs or participates as keynote speaker to related international conferences/forums in Europe, Asia and the USA.

Howard Mendelsohn, Chief Client Officer, Kharon

Howard works closely with business, compliance, and legal professionals to strengthen programs and controls for managing risks at the intersection of global security and commerce. Howard has over two decades of experience in combating illicit financial activity in both the government and the private sector. Howard served at the U.S. Treasury Department from 2001 to 2011, including as Deputy Assistant Secretary and Assistant Secretary (Acting) for Treasury's Office of Intelligence and Analysis.

Howard led Treasury's intelligence functions, including oversight of analytical production, risk assessment, security, and strategic planning. Following his service at Treasury, Howard held leadership positions in Enterprise Compliance at PNC Financial Services Group. He is a recognized thought leader on global security and risk matters and speaks regularly at conferences.