As part of the Annual Compliance Conference webinar series, this session explored the evolving global sanctions landscape in relation to Russia, over three years since the first wave of sanctions following the outbreak of war in February 2022. The panel examined the current state of play, recent developments, and what may lie ahead for businesses navigating this complex environment.
Sanctions developments:
Speakers provided updates on the 17th EU sanctions package (May 2025), including measures targeting the shadow fleet, energy sector, and expanded asset listing criteria. The UK’s April 2025 package introduced new restrictions on sectoral software and intragroup transfers, while Switzerland implemented its 16th package with a continued focus on reporting duties and vessel listings. The US has continued to maintain broad alignment with allies, with recent sanctions targeting Russian oil entities and proposed legislation that could significantly escalate restrictions. The panel discussed the need to keep a close eye on developments, but that at present further sanctions appear likely, rather than any relaxation.
Exiting Russia:
The panel discussed the growing challenges multinationals face in completing exits from Russia, for those companies who have not already exited. Key issues include licensing delays (notably in the US), burdensome approval processes (especially in certain EU Member States and Switzerland), and the expanding lists of sanctioned parties and evolving ownership structures complicating due diligence. Practical considerations such as valuation, buyer selection, and contractual protections were also addressed – with a need to implement robust controls to ensure all steps comply with applicable sanctions.
Looking ahead:
The session considered the potential impact of a ceasefire, peace deal and/or any possible related sanctions relief, including the likelihood of staggered lifting and divergence between jurisdictions. Speakers highlighted the importance of ensuring sanctions compliance as part of any scenario planning, considering stakeholder expectations, and the likely practical difficulties of any direct or indirect re-entry to the Russian market due to banking, insurance, and broader compliance risks. Here’s a link to the previous webinar we did on this topic.
Disputes and enforcement:
The discussion concluded with a focus on the surge in Russia-related disputes, including jurisdictional challenges under the Lugovoy Law, the rise of anti-suit injunctions, and enforcement risks across jurisdictions. The panel also noted the strategic shift by some investors away from formal disputes in favour of negotiated outcomes.
You can access the webinar recording here.
