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Russian Sanctions

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As part of the EU’s 12th package of sanctions against Russia, adopted on 19 December 2023 (see our previous blog post here), the EU introduced a requirement under Article 12g of Regulation 833/2014 which requires EU exporters to include wording in certain goods contracts prohibiting the re-export of the goods to Russia and providing for “adequate remedies” in the event of a breach, in order to combat the circumvention of EU export bans and more…

On Monday 5th June, the EU published an amendment to the existing sanctions against Russia, which came into force on Monday 5th June. The implementing regulation is available here. These measures permit the designation of leading business persons operating in Russia, along with: immediate family members; other natural persons benefitting from them; and business persons involved in economic sectors providing a substantial source of revenue to the Russian Government. These amendments were made on the…

On May 4, 2022, Russian President adopted Decree No. 254 “On interim procedures for the fulfilment of corporate finance obligations towards certain foreign creditors” (“Decree”). The Decree (1) established new restrictions on distribution of profits by limited liability companies, such as, for example, distribution of dividends (before this, the limitation only applied to distribution of dividends by joint stock companies); (2) clarified the application of some of the previously adopted restrictions. New restrictions on distribution…

On 8 April 2022, a draft bill on nationalization of assets belonging to persons associated with “unfriendly” states (“Bill”) was submitted to the Russian State Duma. The Bill defines persons associated with “unfriendly” states very broadly to include foreign citizens and legal entities, their beneficiaries, affiliates and persons under their control. The Bill allows nationalization of all kinds of assets owned by such persons as of 24 February 2022 and located within Russia, including real…