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 in June 2016 here.
Under recently adopted legislation the EU has decided that it needs to further assess implementation of the so-called Minsk ceasefire agreements and therefore the EU has extended certain sanctions against Russia concerning the financial, energy and defence sectors and dual-use goods for another six months, i.e until 31 January 2017.
The application of the EU sanctions regime in the UK is not affected by the outcome of the UK’s Brexit referendum, for the moment at least.
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 for a business 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 the business 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.
André Bywater Cordery, Lexis House, 30 Farringdon Street, London, EC4A 4HH
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