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Sanctions Regimes

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On April 29, 2022 the US Department of Treasury’s Office of Foreign Assets Control (“OFAC”) announced the publication of a Final Rule that reissued and renamed the Ukraine-/Russia-Related Sanctions Regulations (“Reissued Regulations”) and updates to related public guidance. Found at 31 C.F.R. Part 589, the Reissued Regulations took effect on May 2 and have been expanded to include a more comprehensive set of regulations, including additional interpretive and definitional guidance, general licenses, and other regulatory…

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 3 May, President Putin signed Decree No. 252 on Russian countersanctions against individuals and entities of the countries which have imposed sanctions on Russia (“unfriendly states” in the Russian official terminology). In essence, this new Decree introduces the legal framework for blocking sanctions prohibiting: (i) Russian persons (comprising federal and regional state authorities, other state bodies, municipalities, organizations and individuals under the jurisdiction of the Russian Federation) from entering into transactions with (or discharging…

On 27 April, in line with its announcement from 13 April, the Swiss Federal Council imposed further sanctions against Russia and Belarus (see blogpost here). Through these latest revisions of both the Ordinance on Measures connected with the Situation in Ukraine (the “Ukraine Ordinance”) and the Ordinance on Measures against Belarus (the “Belarus Ordinance”), Switzerland has adopted the EU’s latest package of sanctions with a few exceptions (see blogpost here). The new measures entered into…