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Russian Sanctions Spark Investigation at a Global Bank

Following Russia’s invasion of Ukraine in February 2022 and the resulting global sanctions response led by the United States, European Union and United Kingdom, a large multinational financial institution faced heightened regulatory, reputational and financial risk. The bank required a rapid and defensible assessment of its potential exposure to high-risk Russian individuals and entities, including those not yet formally sanctioned but operating through complex structures or third-party intermediaries.

After receiving a minor regulatory inquiry, the bank engaged FTI Consulting to conduct an independent, risk-based investigation to identify and assess these exposures. Through multijurisdictional investigative research and network analysis, the engagement provided the intelligence needed to strengthen sanctions compliance, support client offboarding decisions and mitigate risk amid an evolving geopolitical environment.

Our Impact

The bank responded decisively to heightened sanctions and regulatory scrutiny by rapidly identifying and prioritizing high-risk relationships, preserving its reputation for compliance and avoiding any significant interruption to normal business activities.
In addition to current sanctions, the bank used our actionable intelligence on foreseeable sanctions to support defensible decisions regarding client offboarding, onboarding and remediation.
The bank’s compliance teams were empowered with structured risk assessments and datasets to review customer and transaction records more efficiently and consistently.
As a result, the bank reduced regulatory and reputational risk while strengthening its ability to adapt to ongoing sanctions developments and enforcement expectations.

Our Role

FTI Consulting served as the bank’s independent investigative and risk advisory partner, applying deep sanctions, geopolitical and financial crime expertise to assess exposure to high-risk Russian individuals and entities.
Drawing on our team’s multijurisdictional investigative capabilities, we conducted detailed assessments of political, sanctions, money laundering and reputational risks associated with unsanctioned clients and prospective relationships.
The engagement involved analyzing complex corporate structures and ownership interests, as well as using human source networks built over decades of law enforcement experience to expose blind spots and uncover indirect exposure through third parties, business proxies and affiliated individuals.
Our data scientists leveraged proprietary data sources to produce a list of directors, officers and controlling individuals linked to high-risk Russian entities. We then converted large volumes of semi-structured corporate reports into clean, structured tables, reducing manual research efforts and accelerating the identification of individuals connected to high-risk entities.