Morgan Lewis US and Russia Sanctions Update
Russia's Countersanctions (cont'd)
These specific types of countermeasures are authorized:
termination or suspension of "international cooperation" of Russia and Russian legal entities
with such countries and organizations, in sectors to be determined by decision of the President
prohibition or restriction on import into Russia of products or raw materials that originate from
such countries or are produced by such organizations, with a list of such products / raw
materials to be determined by the Government – and exceptions provided for (i) goods that are
indispensable to life, analogues of which are not produced in Russia (e.g., certain
pharmaceuticals), and (ii) goods imported for personal use
prohibition or restriction on export from Russia of products or raw materials by such
organizations or by citizens of such countries, again with a list of such products / raw materials
to be determined by the Government
prohibition or restriction on performance of public-procurement-type works / services in Russia
for Russian state agencies and certain state-owned legal entities, by such organizations, again
with a list of such works / services to be determined by the Government
prohibition or restriction on participation by such organizations or by citizens of such countries
in Russian privatizations, as well as in performing services on behalf of Russia in connection
with such privatizations of federal state property
and "other measures" by decision of the President (of course, this "catch-all" provision could be
the basis for enactment of possible additional countermeasures, if sanctions-related tensions
deteriorate further)
Morgan Lewis
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