Russian Sanctions Trigger Rapid Exposure and Intelligence Analysis for Banks
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September 18, 2026
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Within days of Russian armed forces entering Ukraine in February 2022, the global community responded by imposing broad sanctions focused on Russia’s military, energy and financial sectors. As Western financial institutions sought to understand any potential exposure to sanctions, FTI Consulting launched a project to examine the full scope of Russian financial and business networks to address acknowledged gaps in typical industry sanctions lists. This intelligence enabled banks to conduct rapid and defensible assessments of potential exposure to high-risk Russian individuals and entities, including those not yet formally sanctioned but operating through complex structures or third-party intermediaries.
Our Impact
- The findings enabled major global financial institutions to effectively search millions of customer and transaction records, conduct deep-dive investigations into potentially suspicious activity and ultimately inform difficult customer offboarding decisions.
- The banks were able to respond decisively to heightened sanctions and regulatory scrutiny by rapidly identifying and prioritising analyses of high-risk relationships, preserving hard-won reputations for compliance and avoiding any significant interruption to normal business activities due to regulatory enforcement.
- In addition to current sanctions, our actionable intelligence on foreseeable future sanctions supported defensible offboarding decisions, identification of potentially noncompliant transactions and remediation efforts.
Our Role
- FTI Consulting experts developed a list of high-risk Russian state-owned enterprises (“SOEs”) in key strategic sectors of the economy and employed media and open sources to fully identify and capture their boards, management teams and controlling individuals in a structured dataset, accelerating the identification of individuals connected to high-risk entities.
- Our business intelligence experts leveraged a substantial human source network to generate leads and obtain additional information on the complex corporate structures and ownership interests of both sanctioned and high-risk individuals, potential business proxies and relationships to Russian political and military stakeholders that could have posed longer-term sanctions, money laundering or reputational risks.
- Our investigative research focused on identifying and analysing adverse media reports on each identified individual and understanding their current business interests, including their source of wealth, to produce risk assessments highlighting areas of concern.
Related Insights
Related Information
Published
September 18, 2026
Key Contacts
Senior Managing Director
Managing Director
Senior Director
Senior Director
