Davis Polk partner Dan Stipano was quoted in Thomson Reuters Regulatory Intelligence on the potential for Russia to use cryptocurrencies to evade sanctions and how banks can mitigate their risk. Dan noted that the same rules that apply to other customers also apply to crypto customers. “So banks would be expected to conduct adequate customer due diligence on their crypto customers: verifying their identity, collecting information to understanding the nature and purpose of accounts, identifying beneficial owners, and monitoring for suspicious transactions and to update information,” he said. In addition, given the evolving nature of the sanctions, Dan said, “It is critical that banks have effective filters in place to ensure that prohibited transactions or accounts are blocked or rejected.”

“Banks with crypto exposure should act to mitigate risk of Russia sanctions evasion – experts,” Thomson Reuters Regulatory Intelligence (March 8, 2022) (subscription required)

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