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Russia Sanctions: Recent Developments and Implications for the Middle East

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The Middle East is an increasingly important jurisdiction for Western governments from a Russia sanctions foreign policy perspective, as there is a perception that increased trade flows between the Middle East and Russia means that Western sanctions are effectively being circumvented. Companies in the Middle East may have concerns about triggering EU / UK / US sanctions jurisdiction, or being directly designated by Western governments for engaging in activities deemed to be contrary to the objectives of EU / UK / US sanctions, even if jurisdiction doesn’t apply.
 
For companies in (or with affiliates in) the Middle East, it is important to understand these measures to contextualise the nature of the demands that Western companies are likely to be making to minimise their potential sanctions exposure. Likewise, for companies trading with entities in the Middle East, there is an onus on taking steps to mitigate the risk of indirectly triggering the Russia sanctions (including diversion of goods to/from Russia). 

In our latest on-demand webinar, we discuss some of the key ways in which EU, UK and US sanctions can target activities in and through Middle Eastern jurisdictions and examples of where Middle Eastern companies have been directly designated by Western governments. Specifically, we discuss:

  • US, EU and UK: Focus on diversion and circumvention;
  • local perspectives: Turkey and the UAE; and
  • key compliance learnings for companies to be aware of.

Click HERE to watch this on-demand webinar now.

If you have any questions, please reach out to our team below.

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Author

Ben Smith is a Partner in Baker McKenzie’s London office and a member of the firm’s Compliance & Investigations and International Trade practice groups. Both these practices are ranked Tier 1 by Legal 500 UK. Ben joined the London office of Baker & McKenzie in September 2007. He has also worked in Baker McKenzie's San Francisco and Brussels offices, as well as on secondment to the legal and compliance teams at three FTSE 100 UK plcs. The Legal 500 UK ranked Ben as a “Rising Star”, noting “Ben Smith is a pleasure to work with. Professional, knowledgeable and always ready to assist with practical solutions.”

Author

Tristan is a Partner at Baker McKenzie, advising clients on sanctions and export controls, anti-bribery and corruption and other corporate compliance risks. He provides compliance advice to clients across these risk areas, including in the context of complex cross-border transactions, as well as supporting clients in the management of related internal and external investigations. Tristan is the UK head of Baker McKenzie’s market leading international trade practice, which is ranked as Tier 1 by Legal 500 and Band 1 by Chambers UK. He is personally ranked as a Leading Individual for ‘Trade, WTO, Anti-dumping and Customs’ by Legal 500 and Band 3 for ‘Sanctions’ by Chambers UK. He is the EMEA Chair of the firm's Investigations, Compliance & Ethics practice.

Author

Terry Gilroy is a partner in the New York office of Baker McKenzie and a member of the Investigations Compliance and Ethics Practice Group. Prior to joining the Firm in 2018, Terry served as Americas Head of the Financial Crime Legal function at Barclays. Terry advises businesses and individuals on white collar and financial crime issues and has significant experience conducting investigations relating to compliance with the US Foreign Corrupt Practices Act (FCPA) and related bribery and corruption statutes, economic sanctions regulations as administered by the US Department of the Treasury's Office of Foreign Assets Control (OFAC), and the Bank Secrecy Act and related anti-money laundering (AML) regulations and statutes. Terry spent six years on active duty in the United States Army as a Field Artillery officer.

Author

Kimberley focuses on international, European and public law governing international trade compliance and sustainability. She advises clients on internal compliance systems, sanctions and embargo regimes, export control law and foreign investment reviews. She accompanies internal and external investigations and self-disclosures of export control and sanctions breaches. In addition, she assists clients in complying with the rapidly evolving EU and German legal landscape on sustainability, in particular the new directives and regulations under the EU Green Deal and the German Supply Chain Due Diligence Act. This includes setting up and improving corporate governance structures and internal compliance programs with regard to environmental, social and governance (ESG) matters.

Author

With close to 10 years' experience in the region, Samir is our Financial Regulation, Compliance & Investigations Counsel for the Middle East and North Africa (MENA), as well as our MENA FinTech & AI Lead. Based in Dubai, his expertise include financial regulation, sanctions, white-collar crime, both advisory and contentious across the MENA region.

Author

Julian Godfray is a senior associate in Baker McKenzie's market-leading International Trade and Compliance & Investigations practices, and is based in London. Julian joined Baker McKenzie as a trainee in September 2014, and qualified in September 2016. Julian has been seconded to two FTSE 100 clients during his time at Baker McKenzie, including in the ethics and compliance team of one client. Julian has also been seconded to the sanctions legal team of a major global investment bank. Julian has also completed secondments to Baker McKenzie's Brussels office in 2016, and more recently to the firm's Madrid office, working as part of the firm's trade compliance practice in Spain.

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