Thursday, June 16, 2022

US, EU, AND UK Sanctions and Export Controls Imposed Against Russia: What Every Business Should Know

On 12 April 2022, the Curtis Sanctions and Export Controls Committee hosted a webinar titled “US, EU, and UK Sanctions and Export Controls Imposed Against Russia: What Every Business Should Know Right Now.”

Curtis’ sanctions experts presented a comprehensive outline of the recent and escalating sanctions and export controls imposed on Russia by the United States, the United Kingdom, and the European Union, starting in mid-February 2022. The presentation details how these measures affect the operations of any business that intersects with Russian entities, Russian economic sectors, and designated Russian persons. Issues covered in the presentation include:

  • Compliance programs and other safeguards in place 
  • Types of international sanctions 
  • Embargoes 
  • Financial sanctions and asset freezes 
  • Prohibition on transacting with listed persons 
  • Trade restrictions (export/import) 
  • Travel restrictions 
  • US Office of Foreign Assets Control (OFAC) penalties for sanctions violations 
  • Penalties can include imprisonment and fines 
  • UK Office of Financial Sanctions Implementation penalties for sanctions violations 
  • EU penalties for sanctions violations
The key takeaway is that all companies operating in this complex and rapidly evolving legal environment should:
  1. Monitor the rapidly changing sanctions landscape 
  2. Establish and maintain a robust compliance program including 
    • Written compliance materials 
    • Employee training 
  3. Screen all transactions diligently 
  4. Be alert for red flags 
    • Geographic 
    • Counterparty-specific 
    • Transaction-specific 
  5. Draft protective contractual provisions 
    • Representations and warranties 
    • Force majeure 
  6. Consider application to agency 
    • Clarification 
    • Specific license
Developments in sanctions laws are sudden and fast-moving, and Curtis would be happy to provide advice and assistance as required. If you would like to watch a recording of the webinar, please click here. The access code is: S@nctions2022. 

To download a copy of the presentation, please click here.