Since early 2014 the EU has imposed various sanctions with regard to Russia in connection with the situation in the Ukraine and the Crimea through a raft of different measures which have undergone expansion and renewal – we reported on the most recent extension (concerning sectoral sanctions) this year here.
Under recently adopted legislation (see here) the EU has reviewed and amended certain sanctions against Russia again, with regard to various individuals and entities, which will continue for six months, i.e until 15 March 2018; under other amending legislation (see here) some latitude for derogation has also been allowed concerning other sanctions with regard to Russia.
Under EU sanctions imposed against Russia, the measures (travel bans and asset freezes) now apply to 149 people and 38 entities.
The application of the EU sanctions regime is not affected in the UK by the Brexit process, at least not for now.
Although both these particular sanctions and other sanctions against Russia (and the Ukraine) have been in place for some time, it is never too late to do a compliance exposure check by undertaking the following:
- A due diligence screening against individuals and entities on the sanctions lists to ensure that your organisation is not doing business with any of these;
- A contracts clauses check on relevant contracts to ensure that provisions concerning warranties, force majeure, termination, and, liability are all up to scratch as regards sanctions; and,
- Where possible and of use (either as an alternative or a complement to contract breach risk), obtain insurance (export credit, political risk, and, trade disruption) against sanctions risks.
- For a summary of the current EU sanctions regime overall with regard to Russia and the Ukraine please look here.
André Bywater is a commercial lawyer with Cordery in London where he focuses on regulatory compliance, processes and investigations.
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