Law360, May 25, 2022
Anthony Rapa and Matthew J. Thomas ●
The wide-ranging sanctions and export controls that the U.S. and its partners have imposed on Russia in recent months pose complex compliance challenges for parties operating across borders, even when there is not a direct or obvious nexus with Russia.
Notably, the U.S. rules include restrictions relating to dealings with sanctioned persons, exports to Russia of a broad range of items, certain services, banknotes, certain imports, and new investment. Furthermore, the annexed Crimea region of Ukraine is subject to a comprehensive U.S. embargo, as are the so-called Donetsk People’s Republic, or DNR, and the Luhansk People’s Republic, or LNR.
This article provides practical guidance for compliance with such restrictions, which can affect commercial operations, investments, and processing of financial transactions.
You can read the full article on our website.