firm has local customer branches in Russia. You know that bank customers (corporate and individual) can set up accounts at these Russian branches, make withdrawals and deposits, take out loans, and complete other banking transactions. You are already aware of AML, KYC, Bank Secrecy, Data Privacy, and Outsourcing restrictions on local banks. However, you have just heard about a new "Localization" requirement that just went into effect this past September 2015. Since you've not heard anything about this before you are concerned about your bank's compliance in that region. You raise the issue to your firm's Compliance Officer who has asked you to research the law, its requirements, timeline for implementation and draft a memo to her that she can share with other senior leaders. She also wants you to provide a list of questions you think need to be asked of the local branch to figure out where they stand in terms of compliance.

• The Compliance Officer specifically wants to know, "what is this new law, does it affect the bank, what does the law mean for us, what are the implications for non-compliance, how do we comply, how can we know our local Russian Bank is in compliance?"
• what would be a good memo suggestion?