Post by Adam Turteltaub

Ever-increasing sanctions of Russian individuals and entities are looking to be a long-term challenge for compliance teams.  That’s not surprising since, they are a part of a war of attrition, according to Oleksandr Pomoshnikov, Head of International Business Development for Ukraine-based YouControl, which offers RuAssets, a tool for tracking Russian and Belarusian assets.

In this podcast he underscores the importance of adopting a three lines of defense model and paying close attention to the origins of funds.  Russian companies have been actively changing beneficial owners to persons in neighboring jurisdictions and opening business units there as well.

This can lead to very complicated and hard-to-trace business structures, he explains, not just because there may be multiple holding companies.  Many of the jurisdictions in the region have closed systems, making it difficult to determine ownership and identify politically exposed persons.

Listen in to learn more.  But do listen carefully.  Oleksander was in Poland with a challenging internet connection while recording.