With these amendments in place, regulated entities—in other words, financial institutions—will be required to report when they determine that property of individuals who have been sanctioned by the Sergei Magnitsky Law is in their possession.
What is the sanction for not doing so? The banks no longer have an obligation to report proactively on a nil return. My concern is that over time, the oversight becomes more and more lax. If in fact a bank, deliberately or even negligently, fails to report, what is the sanction against the bank for not reporting?