The law firm Borenius published an update about the impact of EU sanctions for business in Russia. In their information they underline that the scope of the EU sanctions targeting Russia is complex, especially when it comes to the consolidated groups of companies active within Russia. As the rules are relatively new, there is no relevant case law regarding this issue which could be relied upon in interpretation or guidance.
Although the present situation renders it challenging for any company engaged in trade in Russia to ensure full compliance with the sanctions’ regulations, a risk evaluation and analysis of your company’s activities is recommended. This is particularly important as a possible violation of these rules is subject to penal sanctions.
In addition, more than one sanctions regime may apply to your global business – for instance the US sanctions. The US sanctions have a wider scope of application and the rules are not identical with the sanctions imposed by the EU.
On 8 September, the EU adopted a new package of restrictive measures targeting sectorial cooperation and exchanges with the Russian Federation. Further restrictions were formally adopted by the Council through a written procedure. New restrictive measures will apply from the day following their publication in the EU Official Journal, which has been postponed.
The sanctions are raising contractual, logistical and insurance questions for various parties involved. The Borenius offices in Helsinki, St. Petersburg and New York are closely monitoring the situation. Please follow the updates at: www.borenius.com