IMPROVING SANCTIONS ENFORCEMENT AGAINST RUSSIA: THE CHALLENGE OF 2023 - The most intense year in the history of sanctions listings is over, leaving an intense implementation challenge for 2023. In 2022, Western sanctions programs expanded by forty-two percent. It will not be a surprise to anyone that Russia was the main driver of this unprecedented expansion, now being the target of more than 11,000 sanctions.

In addition to the traditional sectoral and list-based “smart” sanctions, the Group of Seven (G7) implemented a more creative oil price cap policy, intending to limit the price of Russian crude oil to sixty dollars per barrel and minimize revenue flow to Russia’s war chest. Apparently, the oil price cap policy has been working so far, but sanctioning authorities should remain vigilant.

What techniques have sanctioned Russians been using for evasion? What steps should sanctions-wielding authorities take to minimize listing discrepancies and enhance the enforcement? What unintended consequences may we witness as the oil price cap is applied to refined products?

ORIGINAL AIRDATE: 02/13/23