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Countries began to impose export restrictions and economic sanctions (sanctions) against Russia following the attacks in Ukraine during 2022. As a compliance precaution, ESR retrieved all its counterparties, including business partners, investors and vendors, from the Compliance Desktop® system (system). The system helped to examine any exposure to the most recent sanctions imposed on individuals and affiliated businesses in response to the evolving situation.
Our system was able to quickly process the entire database and found no sanctions relating to our counterparties, nor did we detect any potential warning signs of sanctions. In addition, we engaged external legal advisors to assist in our revision and enhancement of our Anti-Money Laundering, Counter-Terrorist Financing & Sanctions Policy. This revised policy complements our system to conduct effective background checks of our counterparties to safeguard ESR’s interests.
