US Sectoral Sanctions

Russia's Countersanctions (cont'd) - There have been a series of statements from the leading Duma sponsors of this proposed legislation, upon dialogue with Russian business leaders and supported by the President's Administration, accentuating that the proposed administrative violation part (assuming this softened part remains as such if/when the bill is enacted) would be meant to cover ➤ only refusal/restriction of "practically automatic"-type business dealings with Russian citizens / entities such as opening bank accounts, or sales that are by law open to any bidders etc. as opposed to more individualized-type dealings such as opening / closing of bank branches (e.g., in Crimea), extending long-term credits This proposed act appears to remain dormant for now Russia also enacted a special SDN-like blocking sanctions edict in 2018, with implementing decree attaching specific designations, against Ukraine - which would have a further tightened regime under the above-noted pending law amendments (slide 87) Gov't Decree No. 1767 of 30 Dec. 2018 includes threat of withholding/removing state pension funds etc. from Russian banks that cooperate with foreign sanctions against Russia (see its art. 2) Morgan Lewis 88

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