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The New Cold War: Risk, Sanctions, Compliance

May 5, 2022

On this week’s episode of “The New Cold War: Risk, Sanctions, Compliance,” Stroock Partner Tom Firestone discusses the new White House proposal to seize Russian assets and use them to “remediate harms of Russian aggression toward Ukraine.”
Tom discusses the following aspects of the proposal:

  • Making sanctions and export controls violations RICO predicates
  • Creating a new streamlined administrative procedure to forfeit assets
  • Making it easier to forfeit property used to facilitate sanctions evasion
  • Expanding the statute of limitations for foreign money laundering cases
  • Making it a crime to possess “proceeds of Russian government corruption”
  • Transferring seized assets to Ukraine