


What kind of power can the United States exert to punish other countries for their misdeeds? The answer, in the age of nuclear weapons, has been economic power. Impose sanctions and cut off access to the U.S. dollar, the thinking goes, and the excruciating economic pain will force a rogue country to play nice.
And yet Russia — by some measures the most sanctioned country on earth — shows little urgency to do what the United States and European nations want: End its war in Ukraine.
Since Russia’s full-scale invasion in 2022, the United States has put more than 6,000 individuals and companies with ties to the Russian war effort on the official sanctions list. For these prohibitions to work, the financial institutions that move money across borders must screen transactions and cut off illicit activity. If they don’t, they could face steep penalties from the United States, including fines or exile to the sanctions list themselves.
Nonetheless, Russia has managed to conduct hundreds of billions of dollars in cross-border trade. One reason could be that the financial institutions necessary to facilitate that trade are not being found and punished.
A New York Times analysis found that eight of the 10 largest settlements for global sanctions violations since 2014, when sanctions were first imposed on Russia over its annexation of Crimea, were against financial institutions. But only two of those cases involved Russia: one against a venture capital firm that managed money for a Russian oligarch who was under sanctions and another against Binance, a cryptocurrency exchange. And Binance was not primarily fined for helping Russia; it had also greased the financial pathway for other countries facing sanctions, including Iran, North Korea, Syria and Cuba.
As for the more than 6,000 entities on the Russian sanctions list, most are individuals and small shell companies; fewer than 30 are large firms based outside of Russia, and only five of those are financial firms.