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Alexander Bychkov

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On May 11, 2022, the Russian Government adopted Decree No. 851 “On measures to implement Presidential Decree No. 252 dated May 3, 2022” (“Decree No. 851”). Decree No. 851: (i) introduced the list of designated persons; and (ii) supplemented the list of prohibited transactions with designated persons. The list of designated persons includes 31 energy companies incorporated in the EU, the US, the UK, Singapore and Switzerland. Notably, most of the designated persons are members…

The text of a draft bill criminalizing compliance with anti-Russian sanctions started circulating via unofficial sources on April 5, 2022. According to the media, it was submitted to the Russian State Duma (lower chamber of Parliament) on April 4, 2022. Currently, Article 201 of the Russian Criminal Code “Abuse of Authority” provides for liability of executives of companies who (a) use their authority against the company’s interests and (b) receive personal gains for themselves or…

Russian President Vladimir Putin has signed a decree on economic measures against the US, other countries and international organizations who have imposed sanctions on Russia (and are therefore treated by the Russian authorities as unfriendly states). In summary, the new Russian retaliatory measures include the following: The following transactions with foreigners affiliated with unfriendly states may be carried out only upon obtaining governmental permits• lending to foreigners (in rubles), except otherwise prohibited transactions;• transactions (operations)…

On February 28, 2022, Russian civil aviation authority (“Rosaviation”) in response to the European states’ ban on flights of civil aircraft operated by Russian air carriers and/or registered in Russia imposed a restriction on flights of air carriers of 36 states. The ban covers aircrafts registered in the following states: AustriaAlbaniaAnguillaBelgiumBulgariaBritish Virgin IslandsGreat BritainHungaryGermanyGibraltarGreeceDenmarkGreenlandFaroe IslandsJerseyIrelandIcelandSpainItalyCanadaCyprusLatviaLithuaniaLuxembourgMaltaNetherlandsNorwayPolandPortugalRomaniaSlovakiaSloveniaFinlandFranceCroatiaCzech RepublicSwedenEstonia