Throughout the month of March, as may have been anticipated, the CFTC and NFA posted a number of updates relating to the conflict between Russia and Ukraine.

March 17, 2022

I-22-11: FCM and IB Members—FinCEN updates its list of FATF-identified jurisdictions with AML/CFT deficiencies

March 09, 2022

I-22-09: FinCEN issues alert on potential Russian sanctions evasion efforts and reminds financial institutions of SAR and other reporting obligations

March 02, 2022

I-22-08: NFA encourages Members to monitor U.S. sanctions on Russia and be vigilant of cybersecurity threats

As the U.S. and other countries around the globe impose sanctions on Russia, it is critical to take a look at all of your banking relationships and third party services providers. Banks such as Socgen and HSBC, international firms that are widely used in the futures space, are not currently following U.S. sanctions. These are just two examples, but of course there are many others.

Because foreign firms may not adhere to U.S. law, particularly foreign banking entities, it is important to consider if any redundant banking relationships should be put in place. This is especially true for firms that have any Eastern European banking relationships.