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BrackenAugust 26 2014

Russia sanctions bring new wave of compliance risks

The speed and scope of sanctions imposed on Russia since the start of the crisis in Ukraine have forced many companies to enhance their compliance infrastructure and rewrite contracts to restrict potential liabilities from sanctions breaches.
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On 31 July 2014, as part of a coordinated effortwith the US, the EU escalated its Russian sanctions regime to ‘phase three’. These wide-ranging sectoral sanctions against Russia apply throughout the EU’s 28 member states and are a response to the ongoing crisis in Ukraine and in particular the downing of Malaysian Airlines Flight MH17.

Since the EU first imposed restrictive measures in response to events in Crimea on March 6, 2014, the scope and nature of the restrictions have become progressively more stringent. What started with an asset freeze and travel ban imposed on a small number of former Ukrainian politicians and mid-ranking civil servants has increased to more than 100 Russian and Ukrainian individuals being subject to an asset freeze and travel ban; 23 Russian and Ukrainian entities being subject to an asset freeze; a ban on the import to the EU of unauthorised goods from Crimea or Sevastopol and further restrictions on business and investment in that region; a Russian arms embargo; and widespread Russian sectoral sanctions relating to the financial services and oil sectors.

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