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The Russian government is preparing to introduce new counter-measures in response to US and EU sanctions. Draft Bill on Russian Countermeasures Last week the State Duma decided to amend Draft Bill No. 441399-7 “On Measures (Countermeasures) in Response to Unfriendly Actions of the USA and (or) other Foreign States” (“Draft on Countermeasures”). As opposed to the initial version of the Draft on Countermeasures, the new version proposes the following five measures: Termination or suspension of international cooperation…

On 1 April 2017, the sanctions-related provisions of the Policing and Crime Act 2017 (the “Act”) came into force, bringing in significant changes to the UK financial sanctions enforcement landscape. As described in our previous blog posts on the subject, the changes brought in by Part 8 of the Act are: A new civil monetary penalties regime under which the Office of Financial Sanctions Implementation (“OFSI”) now has the power to impose civil penalties of…

On 15 March 2017, the President of Ukraine enacted the decision of the Ukrainian National Security and Defense Council (the “NSDC”) to impose sanctions on five Ukrainian banks with the capital of Russian state-owned banks: Sberbank PJSC; VS Bank PJSC; Prominvestbank PJSC; VTB Bank PJSC; and BM Bank PJSC (the “Sanctioned Banks”).1 The Sanctioned Banks are prohibited from transferring capital outside the territory of Ukraine in favour of any affiliated entities. Based on the current…