Crimean Toolkit

Since Russia’s initial invasion of the Crimean-region of Ukraine, the United States has increasingly relied on economic sanctions to apply international pressure on Russia and the current situation makes it clear that the region remains important in both foreign policy and financial institution compliance circles as more sanctions are being applied for additional Russian incursions.

In practical terms, most financial institutions use a basic list of geographic indicators for the Crimean region but given the full integration of the region into the Russian governmental and financial sectors this approach can be insufficient. Perhaps the most accurate information available for identifying Crimea-related locations and persons has been created by the Russian government itself. Chilon Advisory is now making that information available to financial institutions and other persons with sanctions compliance programs.

The Crimean Toolkit includes the name, addresses, identification numbers and controllers (e.g., directors) of corporate entities (a more than 44,000 registered) within what Russia refers to as the “Crimean Republic” and the “Federal City of Sevastopol.” This list, based on official governmental information not provided routinely in other information services, can be uploaded to most automated screening systems for more specific screening purposes. Copies of the underlying original corporate register reports are also provided for reference purposes for use as a part of the investigative, blocking, and reporting processes.

Additionally, the Toolkit includes the identifying information for nearly 900 districts, cities, and settlements within the Russia-controlled area. This information includes not only the name of each such locality, but also the number of persons counted, providing a clear basis for a financial institution to determine the minimum size for each location included as a part of its transaction and customer screening programs based on its risk appetite.

We have also included information from the Russian Communications Agency identifying the telephone number ranges within the sanctioned geography providing an easy method for filtering Crimean numbers from the broader population of numbers assigned within the Russian country code.

Taken together, Chilon’s Crimean Toolkit can help financial institutions and others having an economic sanctions program to evaluate customers and transactions to comply with US law and avoid penalties.

For more information, including pricing, regarding the Crimean Toolkit and its quarterly update cycle, please send an email from a business email address to inquiries@chilonadvisory.com.