Global Trade Review highlighted Laura Deegan's perspective on the U.S. dramatically expanding its list of Russian entities covered by secondary sanctions. "These expanded secondary sanctions can certainly have an effect on a foreign financial institution's willingness to grant a Russian entity a letter of credit or guarantees," Deegan said, further stating," "[In recent months], Treasury officials have also recently spoken to banks across Europe, including Germany, regarding the need for banks to tighten their sanctions compliance programs."