Russian sanctions pose problem for law firms and clients
The crisis in Russia and Ukraine is creating a rapidly-changing sanctions regime in the EU and US, creating real difficulties for companies and law firms, say Susannah Cogman and Elizabeth Head.
September 24, 2014 at 10:45 AM
6 minute read
In July 2014 there was a turning point in the West's response to the political situation in Ukraine. Both the US and EU previously focused on imposing limited asset-freezing measures on Russian and Ukrainian individuals. Within weeks, however, they had dramatically extended their sanctions regimes, targeting specific sectors of the Russian economy.
On 16 July, the US Treasury's Office of Foreign Assets Control (OFAC) imposed restrictions on certain Russian state-owned banks and energy companies to limit their access to capital markets. The sanctions prohibit dealing in debt with a maturity of greater than 90 days issued by the listed companies on or after 16 July 2014. The restrictions also extend to 'new' (ie post-16 July) equity issued by a number of state-owned energy companies.
The EU followed suit on 31 July, introducing its own sectoral sanctions which do not correspond precisely with the US sanctions. When introduced, they applied to a different list of Russian state-owned banks and prohibited transactions in 'new' (post-1 August) "transferable instruments and money market securities" with a maturity of greater than 90 days.
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