Threat of Hard-Hitting Russia Sanctions Leaves U.S. Companies Planning for All Scenarios

U.S. companies with interests in Russia are rushing to draw up contingency plans as Washington threatens sanctions should President Vladimir Putin order troops into Ukraine.

In Washington, lawyer Adam M. Smith in recent weeks has been in daily contact with clients, particularly ones in the banking, transportation and oil-and-gas sectors, concerned about how Russia could be targeted.

“It’s very challenging to sanction-proof your operations [in Russia], especially when you don’t know what kind of actions [from the U.S. government] that would be,” said Mr. Smith, a partner at law firm Gibson, Dunn & Crutcher LLP who specializes in international trade compliance.

The Biden administration last week said the U.S. and its allies are prepared to impose sanctions and export controls on critical sectors of Russia’s economy in response to an attack on Ukraine.

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The Biden administration should be providing guidance publicly and privately to companies, particularly those in the financial sector, on how to comply with measures now under consideration, said Alex Zerden, a former U.S. Treasury official in the Obama and Trump administrations.

Meanwhile, compliance officers should be evaluating sanctions compliance programs based on existing risks and preparing to adapt to new possible actions, Mr. Zerden, now the principal of financial technology and risk advisory firm Capitol Peak Strategies LLC, said.

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