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 (EU extends sanctions against Russian entities and individuals to March 2017) in September 2016 here.
Following the organisation by the Russian Federation of State Duma elections in the illegally annexed Crimea and Sevastopol the EU has decided to add six more individuals to the list of those against whom asset freeze and travel ban sanctions apply. The two legal measures in question can be found here and here, and, the updated total list of both individuals and entities against whom EU sanctions apply can be found here.
Although 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.
For more information please contact André Bywater who is a lawyer with Cordery in London where his focus is on compliance issues.
Office: +44 (0)207 075 1785