BEIJING — KPMG’s China unit completed work for Russia’s sanctioned Sberbank in China, while Bain & Company and EY China explored separate tactics to pursue restricted business, including the use of intermediaries, according to a Reuters review of company documents and interviews, Feb. 3, 2026. The episodes show how big advisory firms are testing the edges of compliance as Western sanctions broaden and Beijing tightens rules over foreign involvement in sensitive sectors.
China sanctions compliance tests grow riskier
Reuters reported that KPMG China agreed to support Sberbank’s China presence in work tied to licensing, government inspections, IT assessments and tax filings, with a fee that exceeded $400,000. KPMG told Reuters the engagement was accepted and performed in line with applicable laws and regulations, adding it conducted sanctions checks and that Sberbank’s Beijing office directly retained and paid KPMG China.
In a separate case, Reuters said Bain’s China team pitched Sberbank on a market-analysis project focused on China’s electric-vehicle sector. Communications reviewed by Reuters indicated a proposed fee above $400,000 for roughly three weeks of work, and discussions included the possibility of using an intermediary because Bain said it could not accept payment from a sanctioned entity. A person familiar with the matter told Reuters the pitch did not succeed and the work did not go ahead.
Reuters also reported that EY staff in China used a third-party firm, Jindian Information Technology (Beijing), to pitch for a strategy project for Chinese state-owned Chongqing Rural Commercial Bank in April 2023. While the contract reviewed by Reuters was between the intermediary and the bank, a person with direct knowledge said the listed project team members were EY China and EY Parthenon employees; Reuters said it verified several identities through public information. A Jindian spokesperson told Reuters the proposal was not accepted, and neither EY nor the bank responded to Reuters’ detailed questions.
Why “workarounds” can collide with China sanctions
Sanctions specialists interviewed by Reuters warned that even when arrangements are structured to avoid prohibited payments or jurisdictions, the reputational and regulatory risk can rise quickly. Daniel Glaser of risk-advisory firm K2 Integrity, a former U.S. Treasury official, told Reuters that dealing with an entity subject to secondary-sanctions exposure can mean “a tremendous risk.”
U.S. secondary sanctions can apply to non-U.S. parties when support is deemed “material,” a judgment that can hinge on facts such as the nature of services provided and how transactions are conducted. The U.S. Treasury’s Office of Foreign Assets Control summarizes the Russia-related framework and targeting priorities in its Russian Harmful Foreign Activities Sanctions guidance, underscoring why firms often treat China sanctions compliance as a board-level issue, not just a local legal box-checking exercise.
At the same time, foreign consultancies are navigating tighter Chinese rules around sensitive work and data. China’s Network Data Security Management Regulations took effect Jan. 1, 2025, adding compliance obligations and restrictions that can complicate cross-border workstreams, according to an overview by Latham & Watkins. For firms trying to preserve revenue in China, the pressure can incentivize “China sanctions” workarounds that still carry significant downside.
The latest report lands in a landscape shaped by earlier turning points: the U.S. Treasury announced full blocking sanctions on Sberbank in April 2022 in a package responding to Russia’s war in Ukraine, according to the Treasury’s press release; Chinese authorities questioned staff at Bain’s Shanghai office in April 2023, Reuters reported at the time; and in mid-2024, Reuters described increasingly complex Russia-China payment workarounds as sanctions widened, including pressure on banks operating in China.
For multinationals, the takeaway is that China sanctions risk is no longer limited to obvious financial transactions. As governments expand enforcement tools and China tightens its own national-security and data rules, compliance teams may face harder calls about where normal commercial “solutions” end and sanctions-evasion risk begins.
