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Managing Sanctions Risk from Russia’s War on Ukraine

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Since Russia began attacking Ukraine on February 24, thousands of people have been killed and over a million people have had to flee their homes, presenting one of the largest refugee crises Europe has ever experienced. In addition to the tragic human losses, the Russian invasion of Ukraine has triggered wide-ranging economic impacts. Among them, the European Union, United Kingdom, United States, Canada, Japan and others have enacted sweeping financial sanctions on Russia in an effort to pressure President Vladimir Putin to end the conflict. These sanctions have targeted Russia’s financial system and its international financial connections by restricting transactions between Russian banks and those in other countries, most notably through the SWIFT global financial network.

The economic impacts of these sanctions will likely affect many industries around the world, whether organizations deal with Russia directly or indirectly through third countries. In a briefing yesterday, global risk consultancy Control Risks discussed some of the risk management considerations and steps companies need to take as the sanctions landscape continues to evolve. According to panelist Henry Smith, partner and head of business intelligence and due diligence in EMEA at Control Risks, there are five key areas risk professionals should focus on to address the risk facing their companies as a result of these sanctions:

  1. What are your nexuses to Russia (including outside Russia)? Organizations need to look at their touchpoints with Russia, including investors and shareholders, lenders and banks, direct and indirect clients, contractual counterparties, and goods and services sourced directly or indirectly from Russia.
  2. Which sanctions apply to your organization?
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    The applicability of sanctions will vary based on your sector, the nationality of the people within the organization, and the currencies you use. It is helpful to note that, currently, there is greater consensus among various sanctions regimes so you may not have to parse through conflicting degrees of severity—consistent sanctions against Russia are being imposed, at least across most Western countries.
  3. What risks are you exposed to? Conduct a risk assessment around which sanctions you are exposed to and whether there are any business activities, relationships or practices you need to end or change in some way. This involves regularly screening Russian counterparties against sanctions lists and undertaking detailed analysis of higher-risk relationships.
  4. How do you respond? Review the implications of any decisions on employees and on contractual obligations, both with direct and third-party clients. Consider any impact winding down activities in one area may have on other business areas. Be sure to engage with regulators, enforcement agencies, banks and insurers for guidance.
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  5. What do you do as sanctions regimes evolve? Sanctions will change in response to security and political developments over the coming weeks and months, so it is important to stay informed of any communications from authorities.
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    Review and read guidance from regulators, enforcement agencies, banks and insurers, and benchmark with industry peers to make sure you can still operate effectively.

Overall, when deciding whether to continue doing business with Russia, companies will need to consider both reputational and ESG-based perspectives as well as practical issues around your ability to do business, such as maintaining the working capital required to continue operations and ensuring that goods and services can still move through the supply chain.

Experts expect that the Russia-Ukraine crisis will have a long-term impact on the global economy and many effects of these sanctions may not be felt for weeks or months. Companies will need to remain vigilant in order to stay ahead of the risks.

RIMS TechRisk/RiskTech: Opportunities and Risks of AI

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On the first day of the RIMS virtual event TechRisk/RiskTech, author and UCLA professor Dr. Ramesh Srinivasan gave a keynote titled “The Opportunities and Downside Risks of Using AI,” touching on the key flashpoints of current technological advancement, and what they mean for risk management. He noted that as data storage has become far cheaper, and computation quicker, this has allowed risk assessment technology to improve. But with these improvements come serious risks.

Srinivasan provided an overview of where artificial intelligence and machine learning stand, and how companies use these technologies. AI is “already here,” he said, and numerous companies are using the technology, including corporate giants Uber and Airbnb, whose business models depend on AI. He also stressed that AI is not the threat portrayed in movies, and that these portrayals have led to a kind of “generalized AI anxiety,” a fear of robotic takeover or the end of humanity—not a realistic scenario.

However, the algorithms that support them and govern many users’ online activities could end up being something akin to the “pre-cogs” from Minority Report that predict future crimes because the algorithms are collecting so much personal information. Companies are using these algorithms to make decisions about users, sometimes based on data sets that are skewed to reflect the biases of the people who collected that data in the first place.

Often, technology companies will sell products with little transparency into the algorithms and data sets that the product is built around. In terms of avoiding products that use AI and machine learning that are built with implicit bias guiding those technologies, Srinivasan suggested A/B testing new products, using them on a trial or short-term basis, and using them on a small subset of users or data to see what effect they have.

When deciding which AI/machine learning technology their companies should use, Srinivasan recommended that risk professionals should specifically consider mapping out what technology their company is using and weigh the benefits against the potential risks, and also examining those risks thoroughly and what short- and long-term threats they pose to the organization.

Specific risks of AI (as companies currently use it) that risk professionals should consider include:

  • Economic risk in the form of the gig economy, which, while making business more efficient, also leaves workers with unsustainable income
  • Increased automation in the form of the internet of things, driverless vehicles, wearable tech, and other ways of replacing workers with machines, risk making labor obsolete.
  • Users do not get benefits from people and companies using and profiting off of their data.
  • New technologies also have immense environmental impact, including the amount of power that cryptocurrencies require and the health risks of electronic waste.
  • Issues like cyberwarfare, intellectual property theft and disinformation are all exacerbated as these technologies advance.
  • The bias inherent in AI/machine learning have real world impacts. For example, court sentencing often relies on biased predictive algorithms, as do policing, health care facilities (AI giving cancer treatment recommendations, for example) and business functions like hiring.

Despite these potential pitfalls, Srinivasan was optimistic, noting that risk professionals “can guide this digital world as much as it guides you,” and that “AI can serve us all.”

RIMS TechRisk/RiskTech continues today, with sessions including:

  • Emerging Risk: AI Bias
  • Connected & Protected
  • Tips for Navigating the Cyber Market
  • Taking on Rising Temps: Tools and Techniques to Manage Extreme Weather Risks for Workers
  • Using Telematics to Give a Total Risk Picture

You can register and access the virtual event here, and sessions will be available on-demand for the next 60 days.

Trade Dispute Worries US Companies in China

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As the Trump administration wages an economic battle with China in the form of reciprocating tariffs and other economic measures, it may not be a great time to be an American company operating in China. The US-China Business Council (USCBC), an organization made up of 200 U.

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S. companies that do business with China, released its annual member survey, finding the trade dispute—and the ongoing political tensions underlying it—are a huge concern for these companies and may be adding to worries about doing business in China.

Since the Trump administration declared a tariff on billions of dollars of Chinese exports in June 2018, the United States and China have traded retaliatory economic measures.

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Negotiators from the countries are preparing to meet in October, hoping to break a deadlock, even as each side moves to put pressure on the other’s economy.

Last month, President Trump announced increased tariff rates on Chinese imports, and tweeted that American companies were “hereby ordered to immediately start looking for an alternative to China, including bringing your companies HOME and making your products in the USA.” Some U.S. business groups condemned the moves and the president’s rhetoric, including the National Retail Federation. “It’s impossible for businesses to plan for the future in this type of environment,” said David French, the federation’s senior vice president of government affairs. These moves are an outgrowth of continued tensions, both economic and political, between the two countries.

It is no wonder then, that between 2018 and 2019, the percentage of USCBC members who said that their company’s business had been affected by US-China “trade tensions” increased from 73% to 81%. Of the reasons companies reduced or stopped planning investment in China in the past year, 60% of respondents cited “increased costs of uncertainties from US-China tensions.”

Among the real-world results of the trade dispute, USCBC members reported that the biggest impact was “lost sales due to tariffs implemented by China” (49%) and “shifts in suppliers or sourcing due to uncertainty of continued supply” (43%). The majority of the other concerns have to do with uncertainty or stigma attached to U.S. companies in China. Additionally, 26% of respondents projected that their current year revenue from China would decrease, compared to 9% in 2018.

The USCBC reported that “respondent optimism about China market prospects five years from now is at a historic low,” with the country’s stringent regulatory environment posing the largest driver of long-term doubt for U.S. companies. Indeed, the survey showed that, for 2019, 14% had a pessimistic or somewhat pessimistic five-year outlook, while 21% were neutral, an increase of 5% for both since 2018. However, the trade disputes are a major driver of short-term pessimism.

Also, when asked about cyber-related issues with doing business in China, 64% of respondents reported that “U.S.-China political tensions” were their biggest worry. And with good cause: According to cybersecurity firm Crowdstrike’s 2019 Global Threat Report, in the past year, the firm “observed an increasing operational tempo from China-based adversaries, which is only likely to accelerate as Sino-U.S. relations continue to worsen.”

And the impact reaches far broader than just companies that do business in China, like the members of the USCBC. As reported in the Risk Management article “The Business Impact of Trump Tariffs,” because many companies have complex, interconnected international supply chains, the trade dispute has a much broader effect on a wider array of businesses and industries. For example, a tariff on Chinese solar panels does not just hurt Chinese solar panel companies, it hurts U.S. manufacturers that supply parts for those panels, and U.S. companies that rely on components from Chinese manufacturers are affected as well.

The Economic Costs of Government Internet Interruptions

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At the end of April, global internet access monitor group NetBlocks reported that Venezuela’s state-run internet provider ABA CANTV was restricting the country’s access to various social media platforms amid continuing demonstrations and political turmoil. In May, NetBlocks reports this has continued, in addition to similar internet limitations in Benin and Sri Lanka. While increased global internet connectivity has led to international economic growth, it has also often led to increased government control over methods of communication and commerce, and government shutdowns pose a serious risk to businesses and economic activity in these countries.

Businesses face a variety of challenges and risks when operating abroad, but internet shutdowns and limitations may present a unique impediment, especially for companies that operate largely online and rely on consistent internet access. With more countries shutting down or limiting access more frequently, companies that conduct business in countries with regular interruptions may need to plan accordingly, or reevaluate whether their operations can accommodate these disruptions. Companies that have internet-dependent supply chains may be particularly susceptible and should ensure they have comprehensive mitigation strategies in place to avoid business interruptions.

Many nations increasingly use internet and social media disruptions as a way to quell political dissent. Some countries have shut down social media after violent incidents, purportedly to curb people’s ability to incite further violence, such as in Sri Lanka after the Easter suicide bombing there. Ethiopia also limited internet access in 2017 after activists leaked copies of the national school exams online. Whatever a country’s motivation, the frequency of shutdowns worldwide is rising dramatically, according to Stastista, which notes a 6,000% increase between 2011 and 2018.

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The Indian government routinely implements shutdowns in various parts of the country, and has in turn suffered serious economic consequences. The Indian Council for Research on International Economic Relations recently reported that, between 2012 and 2017, internet shutdowns in India climbed from 3 to 70 per year, and the shutdowns’ total duration rose from 9 hours in 2012 to 8,141 hours in 2017. According to the report, titled The Anatomy of an Internet Blackout, these disruptions cost the Indian economy approximately $3.04 billion in total. This includes approximately $2.37 billion from mobile internet loss and $678.4 from fixed line internet shutdown.

The Brookings Institution released a study in October 2016 examining 81 short-term shutdowns in 19 countries and their impact on GDP. Between July 1, 2015, and June 30, 2016, the study found that the economic consequences of internet shutdowns cost at least $2.4 billion in GDP globally. The report notes that this is a conservative figure and does not account for tax losses or drops in investor, business, and consumer confidence.

Deloitte also examined the issue in 2016, estimating that the economic consequences of a temporary shutdown “grow larger as the level of connectivity and GDP increase.” For highly connected countries, a temporary shutdown could cut 1.9% of daily GDP—an estimated $141 million per day. Medium-connectivity countries lose an estimated 1% ($20 million) of daily GDP and low-connectivity countries could lose an estimated 0.4% ($3 million) of daily GDP.

A study released in October by Strathmore University’s Center forIntellectual Property and Information Technology Law (CIPIT) showed that shutdowns can also severely impact countries’ shadow economies, often uncounted in formal studies like those from Brookings and Deloitte. According to the report, titled Intentional Internet Disruptions in Africa, unreported economic activity in 49 African countries made up an average of 37.65% of all economic activity. Because this activity is not counted in previous formal studies (like the Brookings study), CIPIT estimates that including these shadow economies increases the total cost of shutdowns by 19% to 29%.

Another Statista study from August 2018 shows that certain countries are shutting down their internet more often than others, most notably India, Pakistan and Iraq. Risk managers should consider these figures and cost estimates when assessing their companies’ existing or potential operations in the countries noted below, or when looking at where to invest overseas.