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David Tannenbaum

Introducing an FCC Alliance

Blackstone has joined together with a slew of our partners, including Pole Star Global, Whitespace, and Paladin Associates to publish a joint advisory on Russia-related sanctions topics.

The anniversary of the Allied victory over Nazi Germany this year brings a new sense of meaning. Europe is now embroiled in war at a scale not seen since World War II. Russia has traded places with Germany to become the new antagonist, and the collective nations of Europe stand side-to-side against this aggression. In the compliance community, we are proud to stand with Ukraine by doing our own part to implement sanctions and facilitate a key prong in our countries’ responses.

This advisory was the collaborative effort of many of our countries’ experts across multiple industries. We come from different firms, specialize in different regions, and provide different types of technologies, investigations, or analysis. But from America to Australia, the United Kingdom to Germany, we stand together in our commitment to self-determination and human rights.

Our explicit goal is to not just focus on the sanctions targets themselves, but to help the compliance community undercut the tactics used to evade those sanctions. Each month we will be focusing on a selection of topics which help compliance professionals better understand the sanctions landscape or overall trends in sanctions risks.

For our inaugural edition, we take on a trio of interesting topics:

  • First, Charles Ike, Olivia Longson (Pole Star Global), and I (Blackstone Compliance) take stock of the maritime industry, including identifying the gaps in various sanctions frameworks and the effects of flag hopping on Russian sanctions evasion.

  • Second, Serge Masters from SDM Group explores how Russian nationals are obtaining Western credit cards from third parties, even after Visa and Mastercard exited the Russian market.

  • Finally, Rosemary Lark from Paladin Associates explains the role that “Kremlin Kids,” the children or close family members of Russian senior officials and oligarchs, play in evading sanctions.

If you have any questions or would like to speak to one of our authors, please do not hesitate to contact us. Likewise, this is an alliance which benefits when its membership swells. If you would like to co-author future advisories, please reach out to me at





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