For some companies engaged in business with Russia, it has proven pragmatic to act as if the country were under more wide-ranging U.S. sanctions than is actually the case. Although not as comprehensive as the sanctions against Iran or North Korea, the U.S. measures against Russia affect fundamental aspects of the local economy, such as the banking system, making any kind of business in Russia effectively difficult to accomplish without violations. Moreover, U.S. authorities have adopted positions that give them a wider potential field of maneuver than they have, in practice, implemented, leaving much to public officials’ own discretion. The U.S. has coordinated its sanctions ever more closely with those of partners such as the E.U. and the U.K. to close off circumvention opportunities. Business with Russia is likely to become more limited as regulators become more proactive and prohibitive. This article distills insights offered by Davis Polk attorneys during a firm webinar addressing sanctions and similar measures taken against Russia by the U.S. Office of Foreign Assets Control, DOJ, Department of Commerce, Financial Crimes Enforcement Network and in Europe, noting compliance challenges and enforcement efforts. For a look at sanctions basics, see our three-part series: “How Sanctions Regimes Work” (Jun. 16, 2022); “Their Impact on Private Fund Investors and Investments” (Jun. 23, 2022); and “How to Comply With Them” (Jul. 7, 2022).