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Crisis Update: Sanctions and Countermeasures


On September 30, 2022, a wide range of questions was discussed at the AEB webinar “Crisis Update: Sanctions and Countermeasures”. The invited speakers talked about the key recent legislative initiatives in Russia, restrictions on transactions, sanctions risk management.

The expert Polina Lebedeva presented an overview of the key legislative initiatives in Russia of the past several months such as reduction of fines for violations of currency regulations, President Decree №430 cancelling the duty to partially sell the currency income, President Decree №520 introducing a ban on selling shares of the specified companies to foreign legal entities linked to the unfriendly states. Polina also shared a list of official sources where legal acts are published.

Andrey Zharskiy, Partner, ALRUD Law Firm, gave the details of application of Decree №618 that restricts for persons from unfriendly countries the ability to make transactions with shares of Russian LLCs. He clarified what transactions are subject to the requirements of the decree, what kinds of transactions (operations) require approval. 

Anastasia Cheredova, Head of Special projects practice, VEGAS LEX, gave practical recommendations how to implement a sanctions risk management system and talked about risk mitigation mechanisms such as checking counterparties, monitoring sanctions, optimizing the terms of the contract.