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Just two months after enhancing the Anti-Money Laundering (AML) Whistleblower Improvement Act, a move largely seen as an attempt to crack down on Russian sanction evasion, the Biden Administration announced new sanctions on Russia and related entities on February 24, 2023. Less than a week later, the US also signaled that sanctions may be coming for China and other countries helping Russia circumvent restrictions, presenting an increasing need for tight supply chain management and awareness of the potential exposure of downstream and upstream partners.
