DOBI Regulated Entities Must Fully Comply with US Sanctions on Russia and Belarus

Advises insurance companies and financial institutions to protect systems against increasing cyber risks, among other actions

The New Jersey Department of Banking and Insurance today ordered insurance companies, financial institutions and other entities it regulates to comply fully with sanctions imposed on Russia and Belarus by the United States. United. The directive follows Executive Order No. 291, issued by Governor Phil Murphy on March 2, directing the department to take action in response to the Russian invasion of Ukraine.

“Our administration is committed to using the full reach of the law to ensure that Russia is held accountable for its brutal and unprovoked invasion of Ukraine,” Governor Murphy said. “This bulletin makes it clear that we expect all entities regulated and licensed by DOBI to comply with the sanctions and restrictions imposed by the Biden administration on the Russian Federation and Belarus.”

Pursuant to Executive Order 291, the department directed regulated entities to monitor all communications from the Office of Foreign Assets Control (OFAC) of the United States Department of Treasury and other federal agencies in real time to keep aware of the latest developments and ensure compliance with the restrictions imposed on Russia and Belarus. The department also advised regulated entities to assess their systems for cyber risk and take appropriate steps to mitigate that risk, given that the Russian invasion of Ukraine significantly increases cyber risk to the U.S. financial sector. .

“New Jersey stands with Ukraine against unprovoked aggression that has resulted in devastation, widespread human suffering and unnecessary loss of life. Under Governor Murphy’s leadership, the state is taking action to hold Russia accountable in the face of this illegal and immoral invasion. There is also a need to ensure that financial institutions operating in our state are protected from increased risks resulting from the invasion,” said Commissioner Marlene Caride.

In addition to specific actions related to complying with U.S. sanctions and protecting against cyber threats, the department’s bulletin directs regulated entities to take additional steps to review, identify and mitigate other types of risks resulting from the Russian invasion. from Ukraine. Specifically, the bulletin directs and reminds regulated entities that:


The Department reminds regulated entities and licensees that they must have policies, procedures and processes in place to implement the necessary internal controls, with appropriate training, risk assessments, testing and audits against their risk profile, and that they should promptly report any suspicious activity. to FinCEN, the U.S. Department of the Treasury, and applicable law enforcement agencies. It is especially important at this time for money transmitters to ensure that their transaction monitoring appropriately identifies designated persons, entities and countries sanctioned by OFAC. Remittance senders who send and receive correspondent banks or pay through accounts located in Russia or Belarus must submit a report to the department within 30 days that includes an assessment of the impact of current sanctions and an implementation plan. work to deal with it.


Russia’s ongoing attacks on Ukraine could affect risks including, but not limited to, market risk, credit and liquidity risk, cyber and operational risk, strategic and other risks . The Department expects risks to be mitigated by a comprehensive risk management process overseen by senior management and the boards of directors of insurance entities licensed to do business in New Jersey, and that risks important are identified in reports to the department. Regulated entities are reminded of their obligation to actively identify and manage risks and actively engage with the Department, as required.


The department’s bulletin also indicates that under various state laws, the department may suspend or revoke the licenses, permits, registrations and certifications of businesses, including businesses owned or controlled by the government of Russia, Belarus or their instruments, and companies that invest directly in such companies.

The bulletin released today by the department can be viewed here:

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