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In this episode of CHATTIN CYBER, Marc Schein interviews Emil Bove, Trial and Investigations Lawyer at Chiesa Shahinian Giantomasi (CSG). Emil has extensive experience working in both the public and private sectors, starting his career as an assistant United States attorney specializing in cyber risk. Today, he speaks about the new sanctions announced against Russia following the invasion of the Ukraine, why Russia might push its financial transactions and assets into the crypto space, cyber enforcement trends pertaining to the same, and the recent collaboration of the private sector and the government sector for speedy cyber law enforcement and protection.
Recently, in the aftermath of the Russian invasion of Ukraine, the US Treasury department announced a lot of sanctions against Russia. One result of that is that banks are trying to comply with the sanctions on both US financial institutions and international institutions, identifying their exposure to the sanction parties, sanction relationships, and figuring out how to address that exposure – whether that’s blocking assets in some instances, or ending client relationships in others. Secondly, we’re anticipating mechanisms for any sanction party to engage in sanctions evasion and access the international financial system and even the US financial system directly through correspondent accounts. Sanction parties need to innovate. Russian parties are also expected to push financial transactions and assets into crypto.
Emil also discusses the trends in cyber enforcement. With Russia likely to venture into the crypto space, care needs to be taken while enforcing sanctions as not everybody is a Russian actor. Clients have to be sensitive to sanctions compliance. Recently, the OFAC has been sanctioning crypto service providers, some of which are based in Russia, who are non-compliant with US expectations for transparency and staying away from ransomware. Both on the regulatory and criminal sides, the government will be looking at public examples of non-compliant actors who are not seeking to implement the sanctions intended to choke back on Russia’s access to the financial system.
Another thing Emil talks about is the private sector’s collaboration with the government in connection with the above sanctions. He predicts that the partnership will be significant because the technological expertise of the private sector can help speed up the government’s work. The technologies used so far have repeatedly shown themselves reliable and trustworthy and have generated accurate results.
For more, tune in to today’s episode!
“There’s a cyber component to the banks trying to comply with the sanctions to both US financial institutions and really international institutions, taking a look at what OFAC is doing. And identifying their exposure to these now sanctioned parties and sanction relationships, and figuring out how to address that exposure, whether that’s blocking assets in some instances, or ending client relationships in others.”
“There are a few understood mechanisms for any sanction party to engage in sanctions evasion, to access the international financial system, and sometimes even the US financial system directly through correspondent accounts. Sanction parties are going to need to take some new steps to do some innovation. And I think that one way that we’re going to see that is Russia as a sovereign, and also just sanctioned Russian parties over there are going to push financial transactions and assets into the crypto space.”
“There’s then now a public opinion that sort of authorizes and endorses law enforcement collaboration with the private sector and use private sector tools in a sophisticated and developing space where government technology, especially in the law enforcement side, may not be quite as up to speed as where the more well resourced private sector parties are endorsing that and I think you’ll see that going forward.”
[00:43] – The journey to becoming an assistant United States attorney
[19:45] – About the US Treasury Department announcing sanctions against Russia [21:49] – The biggest things around cybersecurity being ignored right now
[29:58] – Closing thoughts
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