Measures Against Russia Pose Serious Compliance Challenges

For some companies engaged in business with Russia, it has proven pragmatic to act as if the country were under more wide-ranging U.S. sanctions than is the case. While not comprehensive, U.S. sanctions affect fundamental aspects of the local economy such as the banking system, making any kind of business in Russia effectively difficult to accomplish without violations. Over 1,000 U.S. companies have ceased or curtailed operations in Russia, and business with Russia is likely to become more limited because of regulators’ moves. This article distills insights offered by Davis Polk attorneys during a firm webinar addressing sanctions and similar measures taken against Russia by the U.S. Office of Foreign Assets Control, DOJ, Department of Commerce, Financial Crimes Enforcement Network and Europe, noting compliance challenges and enforcement efforts. See “Russian Trade Under a Microscope: How to Adapt to the Shifting Export Controls and Sanctions Landscape” (Jun. 8, 2022). 

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