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Russian Imposed Sanctions

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On March 7, 2022, the US Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) issued an alert to financial institutions warning about potential attempts to evade US sanctions and other restrictions imposed on Russia and Belarus (“Alert”). The Alert includes red flags that financial institutions should review to help identify potential attempts to avoid sanctions, with a particular focus on convertible virtual currency (“CVC”), and also reminds companies of their reporting obligations under the Bank Secrecy…

The Russian Parliament has adopted a draft law that allows the executive branch to exempt certain goods from intellectual property rights protection. The draft law gives the Government authority to temporarily annul the rules on protection of intellectual property rights in relation to goods or groups of goods specified in the relevant act of the Government or authorized agency. We believe that the measure is likely to apply to certain essential goods, medicines and medical…

From 2 March 2022, Russia introduced special rules for real estate transactions with foreign legal entities and individuals associated with foreign states that adopted measures targeting Russian legal entities and individuals (“Foreign States”): Russian residents may carry out transactions resulting in the change of ownership of real estate assets with (a) the counterparties from the Foreign States and (b) with persons, including Russian and non-Russian legal entities, controlled by such counterparties, only upon obtaining a…

Prohibition on import/export of certain goods On March 8, 2022, the President of the Russian Federation signed an Executive Order, which prohibits the import and export of products and raw materials from the country according to the lists determined by the Russian Federal Government. According to the Executive Order, the ban and restrictions on the import and export of products and raw materials are applied “in order to ensure the security of the Russian Federation…