On June 23, 2023, the European Union published its 11th package of sanctions in relation to Russia. In addition to adding 71 individuals and 33 entities to the list of designated persons which are subject to sanctions, the new package fine-tunes the existing regime, with extensions primarily aimed at combatting circumvention more effectively and

On May 22, 2023, the President of Russia signed Decree No. 364 (“Decree 364”) On Certain Amendments to Decree of the President of Russia No. 430 dated July 5, 2022 (“Decree 430”) requiring Russian businesses who have issued Eurobonds to issue replacement securities to enable holders whose bonds are held through Russian depositaries to receive payments.Continue Reading Russian Obligors Are Required to Issue Russian Bonds Replacing their Eurobonds

On 19 May 2023, the UK expanded its list of Designated Persons under the Russia (Sanctions) (EU Exit) Regulations 2019 by adding 86 new persons, comprising 42 individuals and 44 Russian legal entities. The newly Designated Persons are primarily involved with, or linked to, the defense, transportation, extraction, metallurgy, financial and agricultural sectors of the Russian economy. This expansion of sanctions appears to follow the G7 Leaders’ Statement on Ukraine, which was also issued on 19 May.Continue Reading UK Russian Sanctions Expanded Following G7 Summit

On April 25, 2023, the President of Russia signed Decree No. 302 On Temporary Management of certain assets, including movable and immovable assets and equity interests in the capital of Russian legal entities, that appoints the Federal Agency for State Property Management as the temporary manager of such assets and allows the agency to exercise all the rights of the owner of such assets, other than to dispose of the assets.Continue Reading Tit for Tat Continues, or Further Russian Countersanctions That Allow Nationalization of Assets of Persons From Unfriendly States

The following post was originally included as part of our recently published memorandum “Selected Issues for Boards of Directors in 2023”.

This past year’s Russia-Ukraine conflict sparked a significant transformation of the global economic sanctions landscape, with developments and lessons extending well beyond Russia. 

In 2023, boards of directors should continue to monitor

On December 5, 2022, the maritime services ban targeting Russian-origin crude oil that previously had been announced by an international coalition of countries, including the United States, the European Union, and the United Kingdom, took effect.  While each coalition member has enacted its own measures to give effect to the ban (as we discussed previously here[1]), the measures enacted by the coalition members are generally consistent and include the same major features, namely, a maritime services ban and associated price cap “safe harbor” or exemption.[2]  Since the effective date of the maritime services ban, Russian President Vladimir Putin has issued a decree prohibiting the supply of Russian-origin oil and oil products to certain foreign persons applying the price cap, and OFAC has issued additional guidance relating to the upcoming implementation of the maritime services ban with respect to Russian-origin petroleum products.Continue Reading Recent Developments Regarding the Maritime Services Ban on Russian-Origin Crude Oil and Petroleum Products (with Price Cap “Safe Harbor” or Exemption)

On September 9, 2022, the U.S. Department of the Treasury issued preliminary guidance (Preliminary Guidance) providing the initial outline of a long-anticipated price cap on Russian-origin crude oil and petroleum products (Price Cap), taking effect December 5, 2022 and February 5, 2023, respectively.[1]  The Price Cap is expected to be implemented by “a coalition of countries including the G7 and the EU” and follows an earlier statement of intent issued September 2, 2022 by G7 finance ministers.[2]
Continue Reading U.S. Treasury Department Issues Preliminary Guidance on Russian Oil Price Cap and Services Ban

As the next part of our series of updates focusing on the key disputes and risk related issues arising from the conflict in Ukraine, we have highlighted specific instances where EU companies and executives may be exposed to risks of criminal liability. (Our first update focusing on the effect of the conflict on contractual obligations is here). Whether you are directly affected by these risks, or have a counter party which is constrained by them, it is essential to navigate them effectively.
Continue Reading Russia-Ukraine Disputes Taskforce: Risk of Criminal Liability

We are witnessing a new dispute resolution landscape emerge as a result of the ongoing situation in Ukraine.

We have created a dedicated taskforce of specialists that aims to help our clients through this challenging time as the number of business and legal issues arising from the conflict continues to increase. This includes sharing market experience, insight and providing practical advice. We will examine and share with you in the coming weeks the key disputes and risk related issues we see clients focusing on.
Continue Reading Russia-Ukraine Disputes Taskforce

The United States, the European Union and the United Kingdom, along with a number of other jurisdictions, have responded to the ongoing military conflict in Ukraine by adopting new, additional and/or enhanced economic sanctions, trade restrictions and other restrictive measures targeting, in different ways, Russia, Belarus, and the so-called Donetsk People’s Republic and Luhansk People’s Republic, which Russia has purported to recognize as independent states.  Russia, in turn, has responded to these restrictive measures by adopting its own countermeasures and related regulations affecting, for example, certain dealings involving non-Russians in Russia.
Continue Reading Sanctions Developments Resulting From the Conflict in Ukraine