On November 23, 2018 the Russian Government issued Decrees No. 1403, No. 1404, No. 1405 (“Decrees”), establishing the right of Russian banks and credit institutions that fall under foreign sanctions to not disclose certain information that is normally subject to mandatory disclosure requirements. In particular, the Decrees prescribe such banks and credit institutions to provide information on its shareholders and UBOs only to the Central Bank of Russia and to give motivated explanations.  The Central…

On 22 October 2018, Russian President Vladimir Putin signed a decree calling for countersanctions against Ukraine and instructing the Russian Government to draw up a list of companies and individuals that will be subject to economic restrictions under the new measures and also a list of the respective restrictions. The decree, “On the introduction of special economic measures in connection with the unfriendly actions of Ukraine against Russian citizens and legal entities,” entered into force…

On 4 June 2018, President Putin signed the Federal Law “On Measures (Countermeasures) in Response to Unfriendly Actions of the USA and (or) other Foreign States” (the “Law on Countersanctions”). The Law on Countersanctions entered into force on the date of its publication (i.e., on 4 June 2018). Specifically, the Law on Countersanctions includes the following potential countermeasures: Suspension or termination of international cooperation of Russia and Russian legal entities with (i) unamicable states, (ii)…

Law on Russian Economic Countermeasures On 30 May 2018, the Federation Council (upper chamber of the Russian Parliament) approved the Federal Law “On Measures (Countermeasures) in Response to Unfriendly Actions of the USA and (or) other Foreign States” (the “Law on Countersanctions”).  The Law on Countersanctions was approved in the version adopted by the State Duma in the third and final reading on 22 May 2018. The Law on Countersanctions will be passed to President…