FIS Risk, Information Security and

Compliance (RISC) Solutions

Crimea Sanctions Compliance

Challenges and Solutions

www.fisglobal.com/RISC

May 16, 2017

Robert A. Marro, Jr.

Director, AML & Sanctions Compliance

FIS RISC Financial Crime Advisory Services

Crimea Sanctions Background

• In February 2014, Russian

Federation military troops led by

special operations forces (Spetsnaz)

invaded the Crimea region of Ukraine

and facilitated the annexation of the

Crimean Peninsula by Russia

• In response, President Obama

signed four executive orders

imposing sanctions

• Specifically, Executive Order 13685,

Blocking Property of Certain Persons

and Prohibiting Certain Transactions

with Respect to the Crimea Region of

Ukraine, imposes general prohibition

on certain transactions with all

persons and entities located in

Crimea.

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Crimea Sanctions Challenges

• E. O. 13685 targets a ‘geographical region,’ which is not

a country; it is a disputed area between two countries,

Russia and Ukraine

• The net effect of discontinuing any or all trade

relationships with Russia and Ukraine so as to comply

with OFAC policy would provide highly problematic ‘ripple

effects’ on global politics and economy

• Residents of Crimea consider themselves living in Russia

or Ukraine, depending on their individual political

allegiance

• Addresses in Crimea will not necessarily have the word

“Crimea” in them, yet will still be legally

functional/acceptable, so the single key word check

would not be effective for compliance with E. O. 13685.

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Crimea Sanctions Challenges (continued)

• Names of municipalities in Crimea may be spelled in the Latin

alphabet using transcription from Russian or Ukrainian

language, yielding to different spellings of the localities in

English

• Both Russia and Ukraine are undertaking steps to restore the

historic “Golden Horde” Tatar names of Crimean municipalities;

these names can then be legally used

• Most public sources, such as Google, provide different spellings

of Ukrainian names for the municipalities than those a native

Ukrainian-speaker would use

• Very limited volume of information regarding Crimea and

currently accepted legal names of its geographic locations is

available in languages other than Russian or Ukrainian.

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A Return to the Era of Genghis Khan & the “Golden Horde”

The Golden Horde was the western part of Genghis Khan’s Mongol Empire, 1239 AD

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A Return to the Era of Genghis Khan & the “Golden Horde”

After the Mongol Empire broke up in 1259, the Horde was a functional polity

speaking Mongol Tatar. The Khanate of Crimea was the longest existing part of

the Golden Horde until Catherine the Great annexed it in 1783. This is a scene

from the 1938 Sergei Eisenstein film “Alexander Nevsky” of the Mongol Horde

Khan inviting Russian Prince Alexander to join the Golden Horde, circa 1250 A.D.

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Crimea Sanctions Challenges

A Return to the Era of Genghis Khan and the Golden Horde

Historic Name Convention Example 1 - SEVASTOPOL

• Russian translation - Sevastopol

• Ukrainian translation - Sebastopol

• Crimean Tatar: Aqyar (historic Golden Horde name)

Historic Name Convention Example 2 - SIMFEROPOL

• Russian translation - Simferopol

• Ukrainian translation - Simferopol

• Crimean Tatar: Aqmescit (historic Golden Horde name)

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Crimea Sanctions Compliance Solution

• FIS-RISC has employs professionals qualified both in

Sanctions compliance and in foreign languages to review the

information in both Russian and Ukrainian languages and

derive possible names of municipalities that can serve as

addresses in Crimea.

• We have compiled a full list of over 1,900 municipalities in

OFAC-sanctioned Crimea region, each with two or three

(depending on the status of governmental approval of the

“historic name”) different spellings in English.

• FIS-RISC is monitoring for regulatory changes in

Russia/Ukraine and updates the list as the new names are

approved

• This solution is being offered as a Special List within Prime

software, or as a separate, stand-alone list with ongoing

support

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moreinfo@fisglobal.com | 1.800.822.6758

www.fisglobal.com/RISC

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