Some players looking to bypass Russia sanctions are taking pages from the playbook of Iran and North Korea sanctions evaders, such as the use of front companies to transact in the country.
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Isaias Lima, a managing director at financial services business the Bancorp Inc., said attempts by individuals and entities to help Russia evade sanctions are a concern.
“The expectation is that if you are receiving the data, if you have possession of IP addresses, you have to screen those IP addresses and understand whether or not those transactions are originating from sanctioned countries,” he added.
OFAC has relied more and more on the use of IP addresses as a sanctions enforcement tool, said Orisia Gammell, SAP SE’s chief legal counsel for export control.