A secondary sanctions program against Russia on par with those in place for Iran and North Korea is likely, according to Brad Henry, a partner on Akerman's Economic Sanctions and Export Controls team. Henry provided his thoughts in a new Law360 article, which looks at America's recent round of Russian sanctions aimed at business intermediaries.

This latest wave of sanctions added more than 300 entities over 20 countries beyond Russia, as well as Russian foreign subsidiaries. Henry told Law360 that broad sanctions like this are often the prelude to the secondary sanctions stage.

"I think they're coming," Henry said.