CREATE A CONTINGENCY PLAN FOR POSSIBLE INTERNATIONAL SANCTIONS AGAINST CHINA, SHOULD IT CHOOSE TO ARM RUSSIA

Given that the United States has now declassified information which suggests that that there is a very good chance China will soon decide to sell arms and ammunition to Russia, which means the swift imposition of international sanctions against the PRC, this is the appropriate time to start planning which customers you will choose to closely monitor, to prevent sanctions evasion through your bank.

Compliance offices at North American and EU Member banks should examine their customer lists for:

(1) Customers who have substantial international trade with China in goods and services. (Manufacturing and distribution)
(2) Customers whose corporations appear to be owned by Chinese nationals, both expats and those residing within the PRC. ( trading companies)
(3) Any new accounts opened in the last 60 days, that are conducting financial transactions with Chinese banks. (import-export, financial services)

You have to accept that sanctions evasion pipelines, moving through countries that are on record as neutral in the Russia-Ukraine, or nations that currently assist Iran & Syria evade global sanctions, will now adapt to the enactment of sanctions, by moving their new Chinese operations through a combination of the use of existing routes, and creating & opening new avenues, to avoid detection and exposure.

You will have to ramp up transaction monitoring on your high-risk customers that fall into the three categories listed above, lest they use third parties, and your bank, to evade new sanctions on China. Insure that you are prepared.