In this uncertain time, some global companies are announcing that they are “leaving Russia.” What does it mean to “leave Russia,” and what are the data privacy implications of doing so? Setting aside the broader business, political, and other legal considerations, the following are some initial thoughts on these challenging and rapidly developing data privacy issues. What does it mean for a global company to “leave Russia”? The specifics of the answer to this question…
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…