Foreign financial institutions (FFIs) are receiving visits from senior US officials following up on President Joe Biden’s new executive order (OE) threatening that FFIs facilitating significant transactions relating to Russia’s military-industrial base may expose themselves to US sanctions (Trade-based Financial Crime, 10 January 2023).

US treasury officials last week visited Hong Kong to press Chinese and foreign banks on the island to comply with the EO and are expected to do the same in Europe and Japan too.

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