This memorandum is not intended to be exhaustive and has the sole purpose of providing a preliminary overview of the sanctions imposed, and in the process of being imposed, against Russia, with a particular focus on the sanctions adopted by the European Union and some other countries.
This memorandum is not to be construed as legal advice. An ad hoc analysis should be carried out regarding the applicability of individual sanctions in each specific case.
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Business reccomendations for companies
The sanctions scenario is constantly and rapidly evolving and often appears to be complex.
With this in mind, it is nevertheless possible to provide some general recommendations:
1- Continuous updating on any sanctions that may from time to time be implemented is recommended. In-depth assessment of any applicable sanctions or restrictions is crucial, as it may be necessary to adjust or terminate relations with certain counterparts or in certain geographical areas such as Russia or Belarus.
2- It is suggested to assess the pending legal relationships (including with respect to investors, lenders, assets and contractual counterparties), which may, therefore, have a direct or indirect link with the relevant sanctions;
3- It is suggested to consider whether it is necessary to adjust any of said links and thus to review financing and/or trade agreements;
4- Counterparty screening is suggested with respect to the established sanctions lists, also taking into account the various potentially-relevant countries.
This article is for information purposes only and is not, and cannot be intended as, a professional opinion on the topics dealt with. For further information please contact Lorena Possagno, Luca Dettori and Ekaterina Aksenova.