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3/3/2023

Remarks by Assistant Secretary Elizabeth Rosenberg for Terrorist Financing and Financial Crimes at the Association of W…

U.S. DEPARTMENT OF THE TREASURY
Remarks by Assistant Secretary Elizabeth Rosenberg for
Terrorist Financing and Financial Crimes at the Association of
Women in International Trade.
March 2, 2023

As Prepared for Delivery
A little more than a year ago, my friend, close professional collaborator, and co-panelist today,
Assistant Secretary Thea Kendler, and I were on an urgent tour in Europe sounding an alarm
about what the United States believed Russia was about to do—invade Ukraine. We spoke
with our counterparts about the truly dramatic export controls and financial sanctions we
would put in place to respond. As you all know, Russia launched that war, and we responded—
as we said we would—with over 30 countries implementing the most comprehensive,
multilateral, and complex economic pressure measures in history.
When the war started, many observers—and Putin himself—thought Kyiv would fall within
days. Yet, one year later—thanks to the bravery of the Ukrainian people and armed forces, and
the support of our coalition—Ukraine perseveres in the fight and Kyiv remains free.
Our sanctions have played an important part in this very broad e ort. From the beginning,
they have been designed to constrain the wealth and weapons available to Putin to fight his
war—and to do so in a way that minimizes the harm to our own economy.
Already, we have issued over 2,500 sanctions listings, including massive state enterprises such
as Rostec, the cornerstone of Russiaʼs defense-industrial base, and Mikron, Russiaʼ largest
microelectronics manufacturer and exporter. We have locked down half its foreign exchange
reserves, its largest banks, and constrained how it can earn and spend hard currency.
At the start of the war, Russiaʼs sovereign wealth fund contained $175 billion in liquid assets.
Russia has extraordinarily and unsustainably been burning through its fiscal bu ers, including
15% of that fund last year. This will cause powerful and long-term harm to its economy. Last
year, rather than its forecasted budget surplus, Russia su ered a budget deficit of $47 billion
dollars, or 2.3 percent of its GDP. Further, Russiaʼs financial situation will get worse due to
declining oil revenue, due in part to the recent implementation of a price cap on Russian oil
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3/3/2023

Remarks by Assistant Secretary Elizabeth Rosenberg for Terrorist Financing and Financial Crimes at the Association of W…

and petroleum products—the result of months of intense e ort on the part of my o ice at
Treasury and many, many others throughout our government and a G7+ coalition. This is
having its intended e ect: according to the Russian Ministry of Finance itself, Moscowʼs oil
revenues in January 2023 were nearly 60 percent lower than March 2022.
But Russia will look for ways to work around our measures. The coming year will be about
ensuring that our sanctions architecture is fully enforced and e ective—in particular, by
figuring out and cracking down on the ways Russia evades sanctions. Furthermore, we will
deploy new and novel ways of complementing trade controls with financial constraints to
shut down the evasion and shadowy economic activity Russia seeks to sustain its war e orts.
We are specifically concerned about increases in trade with Russia in the kind of goods that
can be used on the battlefield and those who are aiding designated Russian entities. We are
investigating this type of assistance at the individual, firm, and sector level. We will engage
companies, banks, regulators, and service providers in a series of jurisdictions we assess are
wittingly or unwittingly providing assistance to Russia. This is a broad campaign on which we
are working closely with allies and partners.
To give you an example from one country of focus for us: we are concerned that between July
and November of 2022 United Arab Emirates (UAE) companies exported over $18 million
worth of goods to U.S.-designated Russian entities. Also, between June and November of
2022, UAE companies exported over $5 million worth of U.S.-origin, U.S.-export controlled
goods to Russia, including but not limited to semiconductor devices, some of which can be
used on the battlefield.
These types of figures are the basis for our engagement with the private sector, so that we
can clarify the consequences of violating sanctions and export controls, discuss high-risk
activity, and act when necessary.
Specifically, we have implemented over 100 sanctions for evasion networks across many
jurisdictions—but this is about more than designations. This is about making the choice clear
to companies and banks: you can do business with the countries that constitute more than 50
percent of the worldʼs GDP, and its most convertible and stable currencies, or do business with
those who facilitate Russiaʼs war.
Governments of our coalition partners are also making the point that the cost of doing
business with Russia in violation of our policies is a steep one, and companies and financial
institutions should not wait for their governments to make the decision for them.
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