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6/22/2022

Remarks by Deputy Secretary of the Treasury Wally Adeyemo at the United Arab Emirates Banks Federation Roundta…

Remarks by Deputy Secretary of the Treasury Wally Adeyemo at
the United Arab Emirates Banks Federation Roundtable
June 22, 2022

As Prepared for Delivery
Thank you all for joining me today, and thank you to the UAE Banks Federation for bringing
this group together. Itʼs great to be with you again, seven months since our last meeting.
I want to start by commending your commitment to building robust systems for preventing
money laundering and protecting your institutions from being used for illicit purposes,
including the financing of terrorist activity. I know this is only possible because of the strong
public and private partnership that exists between your government and financial sector,
which Iʼve heard about in meetings with your government over the past two days.
Despite this commitment, the UAE—and other global financial hubs—continue to face the
threat of illicit financial flows. This requires you, like U.S. financial institutions, to adhere to
the highest standards for due diligence. Since our last meeting, the world has changed
dramatically, most notably with Russiaʼs brutal and unprovoked invasion of Ukraine, bringing
new challenges for both governments seeking to hold Russia accountable and for financial
institutions like yours that are responsible for implementing the financial sanctions we
impose.
It is important that we recognize that Russiaʼs violation of Ukraineʼs sovereignty is creating
spillovers far from Ukraine. It has exacerbated global food security challenges and created a
crisis around the world, and in particular in some of the worldʼs lowest income countries. In 36
countries, food inflation is 15 percent or higher. Overall, outside analysts estimate Russiaʼs
e orts to block Ukrainian grain exports could cause the starvation of up to 47 million people.
In response to Russiaʼs unprovoked aggression, the United States and a coalition of more
than 30 countries have placed a set of comprehensive sanctions on the Kremlin. Financial
institutions like those you represent are our indispensable partners in this e ort,
implementing sanctions and ensuring the global financial system lives up to our highest

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6/22/2022

Remarks by Deputy Secretary of the Treasury Wally Adeyemo at the United Arab Emirates Banks Federation Roundta…

commitments—that it is not a refuge for those who undermine principles like sovereignty and
territorial integrity or who endanger the lives of innocent people around the world.
Iʼm here today to thank those who have cooperated in this e ort and to underscore the need
for your vigilance and proactive action in combatting Russian sanctions evasion, including in
the UAE. We know that Russian banks have employed deceptive payment practices and used
shell companies and other means to hide the true nature of their transactions. Financial
institutions must be exceedingly cautious in handling any Russia-related businesses and in
managing the risks associated with financial institutions that have exposure to the Russian
financial system.
Failing to do the su icient due diligence needed to know your customers is not a defense. In
addition, non-U.S. persons may also be subject to U.S. sanctions enforcement if a transaction
involves a U.S. person or has a U.S. nexus. Foreign financial institutions should also be mindful
of OFACʼs authority to target foreign persons for providing “material support” to a sanctioned
entity. This can occur even if none of the entities touch the U.S. financial system and are
located outside the U.S. This “material support” provision exists in the majority of OFACʼs
sanctions regulations, including those related to Russia.
Thank you again for taking the time to speak with me today, Iʼm looking forward to hearing
what youʼve been seeing and the challenges youʼre facing. I want to know what we at
Treasury can do to provide further clarity and enhance your ability to help implement these
sanctions, and to work together to hold Russia accountable.
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