featured graphic for DFPI California Department of Financial Protection and Innovation after COVID-19

DFPI issues guidance regarding Russian sanctions

Following the rapidly evolving situation in Ukraine and Russia, DFPI Commissioner Cloey Hewlett issued a guidance to banks, credit unions, money transmitters, and others on March 4 reminding financial institutions to follow state and federal regulations and be mindful of an elevated cybersecurity risk.

All financial institutions licensed by the DFPI are subject to the regulations issued by the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”). The DFPI guidance notes that virtual currency may be used to avoid sanctions by individuals and entities prohibited from engaging in financial transactions. An elevated cybersecurity risk posed by the war in Ukraine also requires licensees to take steps to mitigate cybersecurity threats and take increased measures to segregate networks for Ukrainian and Russian offices.

The guidance does not supersede any reporting requirements in the event of a cybersecurity incident. Licensed depository institutions are reminded to report cyber security incidents to the DFPI and their primary federal regulator. Incidents should be reported as soon as possible once the institution is aware of it.

At this time, the Department is interested in receiving notices of increased cyber activity even if it does not result in a reportable incident, especially if it is attributable to Russia or Eastern Europe. See the Notice to DBO of Extraordinary Events of Public Interest for additional information.

Institute for the Study of War: Russian Offensive Campaign Assessment, March 17

Russian forces did not make any major advances and Ukrainian forces carried out several local counterattacks on March 17.[1] Russian forces made little territorial progress and continued to deploy reserve elements—including from the 1st Guards Tank Army and 810th Naval Infantry Brigade—in small force packets that are unlikely to prove decisive. Russian forces continue to suffer heavy casualties around Kharkiv, and Russian attempts to bypass the city of Izyum are unlikely to succeed. Russian forces continued assaults on Mariupol on March 17 but did not conduct any other successful advances from Crimea.

Key Takeaways

  • Russian forces continue to make steady territorial gains around Mariupol and are increasingly targeting residential areas of the city.
  • Ukrainian forces northwest of Kyiv launched several local counterattacks and inflicted heavy damage on Russian forces.
  • Ukrainian forces repelled Russian operations around Kharkiv and reported killing a regimental commander.
  • Ukrainian intelligence reports that Russia may have expended nearly its entire store of precision cruise missiles in the first twenty days of its invasion.
  • Russian forces deployed unspecified reserve elements of the 1st Guards Tank Army and Baltic Fleet Naval Infantry to northeastern Ukraine on March 17.
  • Russia may be parceling out elements of the reserve force that could conduct an amphibious operation along the Black Sea coast to support ongoing assaults on Mariupol, further reducing the likelihood of a Russian amphibious assault on Odesa.
  • Ukrainian forces shot down 10 Russian aircraft—including five jets, three helicopters, and two UAVs—on March 16, and Ukrainian forces continue to successfully contest Russian air operations.
This article was released by the Department of Financial Protection and Innovation.