Morgan Lewis US and Russia Sanctions Update
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 2018 act has remained essentially dormant since then - but early 2021
report that it might reactivate
Russia also enacted a special SDN-like blocking sanctions edict in 2018, with
implementing decree attaching specific designations (as amended most recently in
Feb. 2021 adding nine companies), against Ukraine - which would have a further
tightened regime under the above-noted pending law amendments (slide 88)
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
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