Davis Polk partner Dan Stipano was quoted in Thomson Reuters Regulatory Intelligence on banks’ preparations for potential U.S. sanctions against China should the country choose to provide material support to Russia. While banks “can never be proactive enough, especially in the sanctions space,” it would probably be premature for them to focus too much attention on potential U.S. sanctions against Chinese targets, Dan said. “One reason for this is because, until such sanctions have actually been issued, it is impossible to know exactly what individuals, entities, geographies, or activities they will cover. Additionally, compliance resources are finite and banks already have their hands full complying with the Russian sanctions.”

“Banks weigh potential response to any U.S. sanctions against China over Russia ties – experts,” Thomson Reuters Regulatory Intelligence (April 18, 2022) (subscription required)