Editor’s note: This story was published prior to expanded sanctions against Russia announced Feb. 24 targeting the country’s two largest financial institutions, Sberbank and VTB Bank, and almost 90 financial institution subsidiaries around the world in an attempt to bar Russia from the global financial system after it further invaded Ukraine.

Jaclyn Jaeger is a freelance contributor to Compliance Week after working for the company for 15 years. She writes on a wide variety of topics, including ethics and compliance, risk management, legal,...