Following on the heels of the New York Department of Financial Services February 25, 2022 letter to regulated entities regarding the “Escalating Situation in Ukraine and the Impact to Financial Sector,” on March 2, 2022, Governor Phil Murphy issued Exec. Order No. 291 (March 2, 2022) (“EO 291”) which directs the Department of Banking and Insurance (“Department”) to issue bulletins or directives to its appropriate regulated entities, requiring them to fully comply with United States sanctions on the Russian Federation and Belarus, as well as with New Jersey laws and regulations and federal laws and regulations.
To that end, on March 17th, the Department issued Bulletin No. 22-05 directing regulated entities to fully comply with U.S. sanctions, including those on Russia and Belarus, as well as with applicable law. The Bulletin identifies particular vulnerabilities for the banking and insurance industries, respectively, and it notes the risks throughout both industries which can be mitigated by “a comprehensive risk management process overseen by senior management and Boards of Directors of entities authorized to do business in New Jersey,” all as a part of the…
