OUR TEAM
GET IN TOUCH
Harry Clark
GET IN TOUCH
Jeanine McGuinness
GET IN TOUCH
Matthew Moses
The Latest
Navigating Unprecedented Sanctions
New restrictions and practical considerations
for companies seeking to comply with the rapidly changing requirements.
Join the conversation
What sanctions did the U.S., UK, EU and their allies impose after Russia invaded Ukraine?
What should companies know about the economic sanctions and export controls that the U.S., UK, EU and their allies imposed after Russia invaded Ukraine?
What should U.S. companies with Russian employees know about employee equity, such as stock option grants, Restricted Stock Units and Employee Stock Purchase Plans?
Are there restrictions on exports of software with encryption functionality to Russia or Belarus?
FAQs
What sanctions did the U.S., UK, EU and their allies impose after Russia invaded Ukraine?
After Russia invaded Ukraine, the U.S., UK, EU and their allies announced additional, far-reaching economic sanctions and stringent export controls relating to Russia. The restrictions include, among other things, territorial embargoes imposed by the United States, blocking and other sanctions against several major Russian banks and a variety of prominent Russian individuals and other parties.
Learn more: New Russia-Related Sanctions: Considerations for Companies Doing
Business in and with Russia
What should companies know about the economic sanctions and export controls that the U.S., UK, EU and their allies imposed after Russia invaded Ukraine?
The economic sanctions and export controls are far-reaching and unprecedented. In a webinar, our team provided an overview of the sanctions and discussed practical considerations for companies seeking to comply with them. The team also discussed sanctions-related topics of interest to companies in the energy and infrastructure, technology and innovation and finance sectors.
Learn more: Where From Here? Navigating Unprecedented Sanctions
What should U.S. companies with Russian employees know about employee equity, such as stock option grants, Restricted Stock Units and Employee Stock Purchase Plans?
The recent Presidential Decree No. 81 makes it difficult for Russian residents, including those who work for U.S. companies, to buy or receive shares in companies headquartered in countries that have sanctioned Russia. Under a separate measure, Russian residents can’t receive funds in foreign bank accounts, which could restrict the sale of shares or access to sale proceeds. Companies may want to consider avoiding new equity grants
and suspending vesting/exercise of prior offers for the time being.
Learn more: Practical Approaches to Employee Equity in Russia under Presidential Decrees
Elizabeth Zane
GET IN TOUCH
Do U.S. sanctions
affect cryptocurrency and other money services businesses that are based outside the U.S. but have customers in the U.S.?
Can Ukrainian citizens enter and/or remain
in countries outside
of Ukraine?
Do U.S. sanctions affect cryptocurrency and other money services businesses that are based outside the U.S. but have customers in the U.S.?
Yes – and a recent criminal case underscores the risks of non-compliance. The U.S. has said it expects people and companies in Russia to turn to cryptocurrency to try to access the U.S. financial system due to sanctions the U.S. and its allies imposed after Russia invaded Ukraine. The U.S. Treasury Department’s Office of Foreign Assets Control has made clear that companies must comply with sanctions whether they deal in virtual or traditional fiat currency. A recent criminal case in New York highlights the need for financial institutions to comply with anti-money laundering and sanctions laws and regulations. In that case, two executives pleaded guilty to violating the Bank Secrecy Act. The executives worked for a virtual-currency derivatives exchange whose parent company was registered in the Seychelles but operated globally, including in the United States. Prosecutors said the company failed to implement an anti-money laundering program, which includes sanctions-screening components, and that they carried out transactions for customers based in Iran despite U.S. government sanctions on such transactions.
Learn more: Non-U.S. Crypto and Other Money Services Businesses: Have Customers in the U.S.? Beware of AML and Sanctions Compliance Risks
Can Ukrainian citizens enter and/or remain in countries outside of Ukraine?
Immigration requirements vary from country to country for Ukrainian citizens to enter, remain and/or work in a given country. Those requirements are expected to change quickly. We are tracking developments related to requirements for Ukrainian immigrants and refugees in Europe and the United States.
Learn more: Immigration and Mobility Resources for Ukrainian Citizens
Immigration and
Mobility Resources for Ukrainian Citizens
Practical Approaches
to Employee Equity
in Russia under
Presidential Decrees
No Longer a ‘Pipedream’: Are the
Oil and Gas Sanctions on Russia an Opportunity for Hydrogen to Move to the Front and Centre of the Energy Mix?
Non-U.S. Crypto and Other Money Services Businesses: Have Customers in the
U.S.? Beware of AML
and Sanctions Compliance Risks
Expanded Controls
on Encryption Software Exports to Russia
and Belarus
New Russia-Related Sanctions: Considerations for Companies Doing Business in and
with Russia
Are there restrictions on exports of software with encryption functionality to Russia
or Belarus?
The U.S. government has tightened export controls in ways that restrict unlicensed supply to Russia or Belarus of many types of software with encryption functionality. The change means that previously authorized exports and other transfers to Russia and Belarus of software with encryption will generally require a license even if the recipients are private-sector companies with no ties to the military.
Learn more: Expanded Controls on Encryption Software Exports to Russia and Belarus
GET IN TOUCH
Laura Becking
GET IN TOUCH
Konstantin Kasyan
GET IN TOUCH
Mark Beeley
GET IN TOUCH
Lars Mesenbrink
Our team has weighed in on many issues of interest to companies affected by fast-moving events. Here are answers to questions that have come up since the crisis began.
Russia and UkrainE
What Companies Should Know
Since Russia invaded Ukraine, companies have had to quickly adapt to a rapidly changing landscape, especially after the U.S., UK, EU and their allies began imposing unprecedented sanctions. This page provides information to help companies comply with sanctions and navigate some of the many business considerations raised by the war.
Join the conversation
FinCEN Calls for Vigilance Against Anticipated Sanction Evasion Attempts
Civil Forfeiture May
Be Tool in Government Arsenal in Russia Sanctions
New Russia-Related Export, Import,
and Investment Restrictions
Expanded Controls
on Encryption Software Exports to Russia
and Belarus
New Russia-Related Sanctions: Considerations for Companies Doing Business in and
with Russia
Expanded Controls
on Encryption Software Exports to Russia
and Belarus
Employers to the Rescue? Potential Compliance Risks When Helping Male Employees Leave Ukraine
International Sanctions' Impact on Business After Russia's Military Actions in Ukraine
The European Antitrust Enforcers’ Response to the Russia/Ukraine Crisis
The European Commission Facilitates Access to Financial Support From EU Member States For Companies Hit Hard by the War in Ukraine
New Sanctions
Targeting Russia
Russian Exposure: Guidance for Tech Companies
Non-U.S. Crypto and Other Money Services Businesses: Have Customers in the
U.S.? Beware of AML
and Sanctions
Compliance Risks
Expanded Controls
on Encryption Software Exports to Russia
and Belarus
New Russia-Related Sanctions: Considerations for Companies Doing Business in and
with Russia
Civil Forfeiture May
Be Tool in Government Arsenal in Russia Sanctions
FinCEN Calls for
Vigilance Against Anticipated Sanction Evasion Attempts
New Russia-Related Export, Import,
and Investment Restrictions
New U.S. Measures Targeting Russia
Russian Exposure: Guidance for Tech Companies
