March 6, 2014

Juan C. Zarate, a senior adviser at the Center for Strategic and International Studies, was deputy national security adviser and an assistant secretary of the Treasury in the George W. Bush administration. He is the author of “Treasury’s War: The Unleashing of a New Era of Financial Warfare.”

The United States and Europe have issued sanctions in response to recent events in Ukraine. If the goal is to impose real costs and affect Vladi­mir Putin’s calculations, this must be the start of a serious campaign of economic pressure against Russia.

U.S. and NATO military support is not a viable option as the Russian annexation of Crimea appears more likely. But aggressive financial measures could make clear that the West can bite hard even absent a military response — and that continued provocations could lead to real damage to Russia’s economy and prestige. Such an effort, however, will prove more difficult, and perhaps dangerous, compared with other financial pressure campaigns since 9/11, such as that against Iran.

The United States and Europe must agree on what such a campaign seeks to achieve — and understand that this alone won’t roll back the Russian military presence in Crimea. An effective campaign would prove punitive but also could affect the thinking of those with influence around Putin, give teeth to diplomacy, deter further incursions and help buttress allies in Kiev and reassure those who neighbor Russia.

The sanctions announced Thursday must be fully implemented. This includes freezing the assets of Russian officials, institutions and companies implicated in the intervention in Crimea. Europe needs to follow suit with asset freezes and visa bans of Russians responsible for the crisis in Ukraine. But this will not be enough.

There needs also to be a broader effort that marginalizes illicit and suspect financial behavior — not just those activities tied to the invasion of Ukraine. This should be a conduct-based campaign that moves banks and companies to reconsider doing business and investing in Russia.

Such a campaign would entail aggressive investigations of illicit financial activity of Russian interests globally — tied to concerns about money laundering, corruption, tax evasion and links to Russian organized crime. This could include European measures to apply enhanced due-diligence and reporting requirements on Russian entities or individuals with bank accounts or new investments in real estate. Europe applied similar scrutiny in Cyprus during its recent banking crisis.

The U.S. Treasury could lead the isolation of those Russian banks or institutions facilitating criminal activity and sanctions evasion, underwriting missile and chemical trade with Syria’s Assad regime and doing business with Belarus and North Korea. We could use Section 311 of the Patriot Act to name specific banks or classes of Russian business transactions as “primary money laundering concerns.” Companies selling missile-defense technology to countries such as Syria and Iran could be sanctioned, too. All of this could be matched with pressure globally to suspend or cancel Russian military and security contracts.

Pivoting from the European list published this week, financial institutions could heighten scrutiny on Ukrainian and Russian corruption, especially “politically exposed persons” tied to the Yanu­kovych and Putin regimes. The global anti-kleptocracy system could actively be used to find leaders’ assets hidden outside of Russia. Such measures would get the attention of leaders and supporting oligarchs. Finally, the United States could expand the list of human rights violators under the Sergei Magnitsky Rule of Law Accountability Act.

These measures could lead to a broad indictment of Russian illicit financial activity and the integrity of Russia’s system. All of this would impact Russia’s ability to access the global banking and trade systems, imposing direct transactional, investment and reputational costs. Putin knows that his country is vulnerable, which explains some of his moves in recent years to reduce reliance on the dollar in international trade and finance. Taking off the financial gloves would make clear that Russia is risking its long-term economic strength and legitimacy.

But these steps would not be without complications. At a time of weak economic growth, there would be costs on Europe, which relies on Russian energy, trade and investment. Distinguishing between legitimate and illicit financial activity would prove difficult.

And if we use the same playbook against Russia that the United States has used against rogue actors in the past, there is no going back. The Russian financial system would be tainted. Once unleashed, these kinds of conduct-based financial tools are difficult to unwind if a diplomatic solution is reached.

Ultimately, the United States would be moving to isolate a country that it has tried for the past decade to make a partner in the global effort to counter money laundering and terrorist financing. This could undermine cooperation on the financial isolation of Iran, North Korea and other rogue actors, with Russia perhaps serving as a safety valve for suspect financial relationships.

A dangerous financial war could also be unleashed. In the past, Russia has used its gas and oil supplies as coercive weapons against Ukraine and Europe, wielded cyberattacks against Georgia and used tax investigations to silence critics. Moscow could retaliate against Western companies and banks doing business in Russia. The Kremlin could enlist hackers and organized criminals to disrupt financial systems and companies in the West.

In a globalized system, the West has vulnerabilities too, and the domain of financial warfare is not the sole province of the United States. Russia knows this.

Financial tools could impose real costs on Russia. We just need to be prepared to wage a sober and calibrated financial campaign against an adversary that has the ability to bite back.

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