Last Friday, Commissioner Clothilde V. Hewlett issued guidance concerning the "situation in Ukraine and Russia".   The guidance reminds licensees of their obligations under federal, and to a lesser extent, California law.  The guidance mentions three areas of concern: sanctions, virtual currency and cybersecurity.  I was somewhat taken aback by the guidance reference to the "situation", but in several places, the guidance refers to the "Russian invasion".

With respect to virtual currency, Commissioner Hewlett notes that the Russian invasion "significantly increases the risk that listed individuals and entities may use virtual currency transfers to evade sanctions".   She advises that all licensees engaging in financial services using virtual currencies should have policies, procedures, and processes to protect against the unique risks that virtual currencies present.

When Russia Came To California

In may come as a surprise that Russia once had plans to expand into California and even occupied a fort here for nearly three decades.  Fort Ross, now a California state park, is situated on the California coast about 60 miles north of San Francisco.  It was established in 1812 and represents Tsarist Russia's southernmost settlement on the North American continent.  The name of the fort is derived from the word "Russia", which is derived from the name of a medieval people known as the Rus.