The text of a draft bill criminalizing compliance with anti-Russian sanctions started circulating via unofficial sources on April 5, 2022. According to the media, it was submitted to the Russian State Duma (lower chamber of Parliament) on April 4, 2022. Currently, Article 201 of the Russian Criminal Code “Abuse of Authority” provides for liability of executives of companies who (a) use their authority against the company’s interests and (b) receive personal gains for themselves or…
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…