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RIO outlines country‑risk framework; cites OFAC and CFIUS as primary controls

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Summary

The Retirement and Investment Office described a country‑risk monitoring framework, use of external advisors, and reliance on federal authorities — including the Office of Foreign Assets Control and CFIUS mechanisms — to guide investment decisions about foreign exposures.

Scott Anderson, Chief Investment Officer, described a country‑risk program the office developed after Russia’s invasion of Ukraine and said RIO relies on external geopolitical advisors and federal regulatory direction to manage national‑security exposure.

Anderson said it is “very difficult for investment professionals to make decisions that are based on national security interest” and noted the office prefers to rely on regulatory bodies. He listed the Office of Foreign Assets Control (OFAC), the Foreign Investment Review Modernization Act (the committee referenced inbound review mechanisms commonly called CFIUS), the International Emergency Economic Powers Act and the Securities and Exchange Commission as primary federal mechanisms that affect what a U.S. public investor can legally hold.

How the office approaches risk

RIO uses qualitative and quantitative country risk scoring — combining economic, financial and political factor scores — and brings assessments to the State Investment Board and the investment committee. Anderson noted that typical indexes (for example MSCI All Country World ex‑U.S.) and major institutional investors influence which countries are included in diversified allocations and that OFAC prohibitions already exclude investments tied to Russia, Iran, North Korea, Cuba and Venezuela.

Operational changes to reduce exposure and increase agility

Treasury and RIO staff described a shift toward separately managed accounts and bespoke manager agreements to improve operational agility and the ability to divest quickly from prohibited or high‑risk holdings. Anderson said separately managed arrangements give the state customized guidelines and the ability to exit positions more quickly than with commingled funds.