Morgan Lewis US and Russia Sanctions Update
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EU Direct Sanctions (SDN-like, etc.)
The EU's SDN-like "blacklist" Reg. No. 269/2014 of March 2014, and with updates
And more names have been added in several update regs. to date
Individuals and entities, including those added
in January 2020, in connection with Crimean elections
in March 2019, in connection with the Ukraine/Russia Kerch Strait naval incident
in 2018, in connection with construction of Kerch Bridge (to Crimea)
in 2017 per the Siemens turbines affair
All dealings with the blocked assets of listed persons (or their subs or certain other affiliates) etc. are
generally prohibited
And see EU Commission Opinion of 19 June 2020 re financial and other transactions with non-blacklisted /
designated entities that are owned or otherwise controlled by a blacklisted / designated person per Reg.
269/2014
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Note the broad "control" understanding, including management and/or financial control or major influence reflected
here) - this ruling not being specific to the Russia sanctions
And similar standard at Section 4.1 of UK June 2020 General Guidance
Currently in effect to 15 Sept. 2021 (extended as of 12 March 2021)
And several Russians (in connection with the 2018 Skripal poisoning in England, and now the Navalny
poisoning in Russia)
are on the EU's new list of chemical weapons proliferation/use violators as of Oct. 2020
and now 2 March 2021 designations of four state officials under new EU human rights sanctions regime (see slide 12)
Morgan Lewis
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