The reality for companies operating in Latin America and the Caribbean is that due diligence and compliance with sanctions is getting much more complicated than it was in the past. There are many more sanctions, longer lists of specially designated entities, and greater number of secondary sanctions with potentially overlapping jurisdictions. An example is the already-mentioned US announcement of sanctions against Russia immediately after the Russian invasion of Ukraine. In close cooperation with the EU, G7 countries, and Australia, Washington designated over 400 individuals and entities including Russian elites, 300 members of the Duma (Russian parliament), and defence companies. The targeting countries also formed what has been called the ‘price cap coalition’ to limit the price of Russian crude oil exports to no more than US$60 a barrel.
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