Morgan Lewis US and Russia Sanctions Update

Russia's Countersanctions Russia's 2020 "anti-sanctions disputes law" and developing Russian court practice on this - see slide 13 Russia enacted in 2018 a law "On Measures (Countermeasures) against Unfriendly Actions of the United States of America and/or Other Foreign Governments", (the "Countermeasures Law" - full text is here, unofficial English translation available on request), which provides essentially as follows: Basic thrust is not to impose automatically - but rather to authorize the President or the Government to institute - various countermeasures (bans on import of goods/work/ services, export bans, etc.) upon finding of justification in anti-Russia sanctions measures (presumably including already-effective and possible future ones) of the US and other countries that commit unfriendly actions "as well as against organizations located in the jurisdiction of [such countries], directly or indirectly controlled by [such countries] or affiliated with them, officials and citizens of [such countries], in the event such organizations, officials, and citizens are involved in the commission of unfriendly actions" vs. Russia Thus, this Law as enacted may well not have substantial effect on international trade with Russia, unless/until the Western sanctions and/or general political relations worsen to an extent deemed sufficient to trigger discretionary Russian executive actions under the Law But wording uncertainties (see above and next slide) awaits authoritative interpretation and/or practice to clarify Morgan Lewis 86

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