E-Bulletin. Russian Economic Sanctions: A Long Road Ahead?
|
|
- Stewart Mason
- 5 years ago
- Views:
Transcription
1 E-Bulletin Russian Economic Sanctions: A Long Road Ahead? Russia cannot simply be allowed to invade its neighbours and shift Europe s borders with impunity, the [economic sanctions] measures under discussion in Washington and Brussels should be much tougher than previous sanctions Every member of Russia s craven parliament, security services and government should face visa bans and asset freezes. The off-shore assets of top Russian kleptocrats should be identified and seized. Russia s energy and defence sectors must be squeezed and it sovereign bonds should be shunned. Western lenders should not finance Mr. Putin s warmongering The Economist: The Long Game : Leader of September 6, 2014 While the tone of the above recent editorial comment from The Economist might appear to some to be somewhat extreme, it is an indication of the increasing fear of many in the West that recent Russian belligerence in Ukraine is only a prelude to further aggressive activities by Russian agents in other countries bordering its territory. The evolution of the international political scene since the beginning of 2014 has confirmed once and for all, that the democratic reforms that most in the Western world hoped to see take place in the former Soviet Union have ground to a halt and now show signs of being reversed in many respects. Countries bordering the former Soviet Union, as well as those that were once part of the USSR, ranging from the three Baltic states of Estonia, Lithuania and Latvia to the Central Asian states of Kazakhstan and Mongolia, have been given good cause to worry about future Russian political and military initiatives with regard to their territory. The latest country to experience Russian military aggression is Ukraine, Georgia having been the object of military incursions into its territory The Ukrainian situation is infinitely more dangerous because of the far greater numbers of people involved and the close ties Ukraine enjoys with its Western European neighbours. The signature of a treaty with the European Union promising closer economic and trading ties was one of the major factors prompting the Russian intervention in eastern Ukraine. Russia s actions have aroused deep concern among Western countries that are members of the NATO alliance. Many NATO members, including Canada, have imposed economic sanctions on Russia in retaliation for its violation of international law in relation to its covert support for secessionist rebels in eastern Ukraine. The apparent unwavering determination, and it must be
2 said considerable success, of Russia in supporting the continuing unrest in Ukraine points to a longer term struggle. Europe once again seems to be dividing along ideological lines. Growing Russian belligerence will likely engender further strengthening and expansion of the scope of the existing sanctions-related restrictions on exports to Russia and to areas occupied by the Ukrainian rebels. Economic sanctions, whatever their alleged effectiveness, are very likely to be a continuing and perhaps growing factor in international trade relations. Companies doing business in Eastern Europe and elsewhere will have to be fully aware of the scope and application of such sanctions as well as the potentially severe penalties that can apply for violation of sanctions rules. Canadian Sanctions In the case of Canada, the Russian annexation of Crimea and the subsequent covert Russian support of separatist insurgents attempting to secure the secession of parts of eastern Ukraine from the rest of the country, have triggered the imposition by the Government of Canada of various economic sanctions. Such sanctions apply in respect of both the Government of the Russian Federation as well as senior Russian government officials and certain selected Ukrainian and Crimean political figures. These sanctions are contained in three separate regulations. The Special Economic Measures (Russia) Regulations SOR/ of March 17, 2014, as amended, and the Special Economic Measures (Ukraine) Regulations SOR/ also of March 17, 2014, as amended, were passed pursuant to the Special Economic Measures Act S.C. 1992, c. 17, as amended. As well, the Freezing Assets of Corrupted Foreign Officials (Ukraine) Regulations SOR/ of March 5, 2014 was passed to counter the misappropriation of Ukrainian state funds or legal acquisition of property of officials of the former regime of Victor Yanukovych, who was deposed following repressive measures undertaken by his government in 2013 against members of the Ukrainian opposition. The Russian and Ukrainian Regulations both impose asset freezes on "designated persons" whom Canada and its NATO allies have determined to have engaged in activities that "directly or indirectly facilitate, support, provide funding for or contribute to a violation or attempted violation of the sovereignty or territorial integrity of Ukraine or that obstruct the work of international organizations in Ukraine". There are now three separate schedules of such "designated persons" appended to the Regulations, an unofficial consolidation of which is appended as Annex 1 to this Bulletin. Section 3 of the Regulations contains a broad prohibition against dealing in the property of designated persons, facilitating such dealings, providing or acquiring financial services to or for
3 the benefit of citizens and persons and making "any goods, wherever situated" available to a designated person. This section then is a relatively complete prohibition on selling to or buying from such designated persons. Section 5 amplifies the application of the provisions in section 3 by prohibiting "any person in Canada and any Canadian outside Canada" to do anything that quote causes, assists or promotes or is intended to cause, assist or promote" any act prohibited under section 3. Subsections 3.1 contains a prohibition on new debt financing of longer than 90 days maturity in relation to Gazprombank and Vneshekonombank which are listed as designated persons for purposes of this subsection. Similarly, subsection 3.2 prohibits new equity financing in relation to ownership interests, and property or rights and interests in their property of Gazprombank and Vneshekonombank. The Freezing Assets of Corrupt Foreign Officials (Ukraine) Regulations, SOR/ came into effect on March 5, These Regulations provide for the freezing of funds and economic resources of former President Viktor Yanukovych and 17 other prominent former Ukrainian government ministers, senior officials and businessmen. The Regulations freeze the assets of these 18 individuals by prohibiting the following actions by any person in Canada, or by any Canadian outside of Canada: dealing, directly or indirectly, in any property, wherever situated, of a politically exposed foreign person; entering into or facilitating, directly or indirectly, any financial transaction related to a dealing with any property of a politically exposed foreign person; or providing financial or other related services in respect of any property of a politically exposed foreign person. There is also an obligation under the Freezing Assets of Corrupt Foreign Officials (Ukraine) Regulations to disclose to the Commissioner of the Royal Canadian Mounted Police any property, or information about a transaction in relation to property, that is believed to be the property of a politically exposed foreign person. The Minister of Foreign Affairs may issue a permit to carry out an activity or transaction that would otherwise be prohibited under the Russian and Ukraine SEMA Regulations or the Freezing Assets of Corrupt Foreign Officials (Ukraine) Regulations. There are two sets of due diligence requirements under the Regulations. Section 6 provides that virtually all financial institutions in Canada must determine "on a continuing basis" whether or not they are in possession or control of property owned or controlled by any of the designated persons. All other persons are not under this continuing due diligence requirement.
4 However under section 7, "every person in Canada and every Canadian inside Canada" must disclose "without delay" to the RCMP the existence of property in their possession or control that they have" reason to believe is owned or controlled directly or indirectly by designated persons or an entity owned or controlled by such persons as well as any information about transactions or proposed transactions in respect of such property. The practical effect of this is that any employee of a company based in Canada and any Canadian employees of that company outside Canada are under an affirmative obligation to disclose any information may have regarding any property in their possession or control that they reasonably believe to be owned or controlled by a designated person. Export Control List There is another aspect to the Canadian sanctions program however that is not covered by the above Regulations but which nonetheless is of equal concern. That is the apparent extension of certain prohibitions under Canada's export control legislation under the Export and Import Permits Act R.S.C., 1985, c. E-19 and the Export Control List published pursuant to that Act. Interestingly, the Canadian government, unlike its US and European Union allies, has refrained from publicizing the increased scope of prohibitions under this aspect of its Russians sanctions program to any significant extent. There is no "Notice to Exporters" on the DFATD website. On August 6, 2014, Prime Minister Stephen Harper announced additional economic sanctions and travel bans against designated individuals. The relevant section of his Statement provides: "Export restrictions announced by the European Union with respect to military and military dual use goods destined the Russia, are already in place in Canada. We are also committed to imposing the necessary regulations to enact export restrictions on technologies used in Russia's oil exploration and extraction sector. Those will be implemented in parallel with our allies." What this indicates is that there are already Canadian export restrictions in place in relation to military and military dual use goods destined to Russia. However the second sentence indicates the Canada is "committed" to imposing necessary regulations to enact export restrictions on technologies used in Russia's oil exploration and extraction sector. Those will be implemented in parallel with our allies." This statement was made on August 6, On September 16, 2014, the Canadian government announced asset freezes and travel bans against four additional Russian individuals and economic sanctions against five Russian defence product manufacturers and one financial
5 institution. However, as of this date there is still no notice as to the actual imposition by the Government of Canada of controls on exports of oil exploration and extraction technology. US and EU Sanctions As noted above, the Canadian government has committed to imposing export restrictions on technologies used in Russia's oil exploration and extraction sector "in parallel with our allies". The already-published sanctions programs of both the EU and the US provide useful guideposts as to future Canadian government action in this area. Given the commitment by Canadian Prime Minister Harper to imposing export restrictions in parallel with Canada's NATO allies, it would seem to be only a matter of time before the scope of existing Canadian economic sanctions is expanded, particularly in relation to goods controlled under the Export and Import Permits Act. As noted above, US sanctions appear to cover both oil and gas technology and equipment for use in deep-water (more than 500 feet), Arctic offshore or shale formations in Russia effective August 1, On September 12, 2014, pursuant to Executive Order 13662, the US government extended the scope of its export controls to cover the Russian defense production sector as well as additional parties and additional activities in the Russian energy sector. Similarly, the EU announced the imposition on September 12, 2014 of further restrictions on dual use goods and technology destined for specified entities in Russia, the provision of services in relation to projects for deep-water exploration and production, Arctic oil exploration and production and shale oil projects, services related to goods and technology listed in the "common Military List" and access to capital markets. As well, EU has expanded the list of designated parties subject to sanctions. The EU sanctions cover the same type of technology and equipment destined for the same applications but they exclude gas-related technology and equipment. The expansion of the scope of US and European Union sanctions will also be of interest to any Canadian company with operations in either the US or the EU. As well, any persons located in the jurisdiction of the US will be fully subject to the application of US sanctions legislation in relation to any activity relating to exports to Russia. The above material is provided for information only and does not constitute legal advice in relation to any of the matters discussed. Sills Egsgard LLP is a Toronto-based law firm specializing in international trade and investment and related regulatory compliance issues. We would be happy to discuss specific legal issues in this area with interested parties. Visit for more information.
Impact of Canadian Economic Sanctions, Trade Controls and Anti-Corruption Laws on the AML Compliance Function
Impact of Canadian Economic Sanctions, Trade Controls and Anti-Corruption Laws on the AML Compliance Function ACAMS Toronto Chapter Lunch & Learn: Managing the Money Laundering Risk of Offshore Money Flows
More informationRussia Sanctions United States by Swedish Club and Leigh Hansson, Partner, Reed Smith LLP, Reed Smith Shipping Sanctions 16 April 2018
Russia Sanctions United States by Swedish Club and Leigh Hansson, Partner, Reed Smith LLP, Reed Smith Shipping Sanctions 16 April 2018 1. Background 1. U.S. sanctions in relation to Russia and Ukraine
More informationPUNISH RUSSIA US CONGRESS HITS THE RUSSIAN ENERGY SECTOR
10/26/2017 US CONGRESS HITS THE RUSSIAN ENERGY SECTOR The Warsaw Institute Foundation Introduction The Countering America s Adversaries Through Sanctions Act (CAATS), which was adopted with near unanimous
More informationUkraine-/Russia-Related Sanctions Update and Overview: U.S. and EU Reaffirm Sanctions
Ukraine-/Russia-Related Sanctions Update and Overview: U.S. and EU Reaffirm Sanctions August 8, 2016 By Jennifer M. Smith, Stewart and Stewart In July 2016, President Obama and Secretary of State John
More informationCOUNCIL DECISION 2014/512/CFSP of 31 July 2014 concerning restrictive measures in view of Russia's actions destabilising the situation in Ukraine
31.7.2014 L 229/13 COUNCIL DECISION 2014/512/CFSP of 31 July 2014 concerning restrictive measures in view of Russia's actions destabilising the situation in Ukraine THE COUNCIL OF THE EUROPEAN UNION, Having
More informationOFAC Ukraine-Related Sanctions: Overcoming Compliance Challenges, Meeting Evolving U.S. and EU Sanctions
Presenting a live 90-minute webinar with interactive Q&A OFAC Ukraine-Related Sanctions: Overcoming Compliance Challenges, Meeting Evolving U.S. and EU Sanctions WEDNESDAY, SEPTEMBER 10, 2014 1pm Eastern
More informationEU Sanctions Update. Chiara Klaui Senior Associate International Trade May 21, 2015
EU Sanctions Update Chiara Klaui Senior Associate International Trade +31 6 4617 8558 May 21, 2015 Baker & McKenzie LLP is a member firm of Baker & McKenzie International, a Swiss Verein with member law
More informationGroup Sanctions Policy
Group Sanctions Policy 1. Purpose This Policy provides instruction with regards to the treatment of, and compliance with, sanctions or restrictive measures imposed on countries, territories, entities,
More informationCross-Border Regulatory and National Security Client Alert:
August 3, 2017 CONTACT Dara Panahy Partner +1-202-835-7521 dpanahy@milbank.com Bijan Ganji +1-202-835-7543 bganji@milbank.com Lafayette Greenfield +1-202-835-7564 lgreenfield@milbank.com Santiago Zalazar
More informationCongress Readying Russia Sanctions: Implications for U.S. Nuclear Commerce. Aleksandar Dukic Ari Fridman June 28, 2017
Congress Readying Russia Sanctions: Implications for U.S. Nuclear Commerce Aleksandar Dukic Ari Fridman June 28, 2017 Agenda Overview of Existing U.S. Russia Sanctions Summary of Russia Sanctions Legislation
More informationSECURITIES LITIGATION & REGULATION
Westlaw Journal SECURITIES LITIGATION & REGULATION Litigation News and Analysis Legislation Regulation Expert Commentary VOLUME 20, ISSUE 12 / OCTOBER 16, 2014 EXPERT ANALYSIS Sanctions Update: Sectoral
More informationWhy Russia breaks the sanctions mould. Ross Denton, Partner, Baker & McKenzie LLP
Why Russia breaks the sanctions mould Ross Denton, Partner, Baker & McKenzie LLP ross.denton@bakermckenzie.com http://www.bakermckenzie.com/sanctionsnews/ Baker & McKenzie LLP is a member firm of Baker
More informationAgenda SCCE ECEI Why Russia breaks the sanctions mould. What are we going to cover? Ross Denton, Partner, Baker & McKenzie LLP
Why Russia breaks the sanctions mould Ross Denton, Partner, Baker & McKenzie LLP ross.denton@bakermckenzie.com http://www.bakermckenzie.com/sanctionsnews/ Baker & McKenzie LLP is a member firm of Baker
More informationInternational Sanctions: where are we now? TOM CUMMINS 13 JUNE 2017
International Sanctions: where are we now? TOM CUMMINS 13 JUNE 2017 Introduction TOM CUMMINS Tom Cummins Partner T +44 (0)20 7859 1051 M +44 (0)7900 890 679 tom.cummins@ashurst.com Partner in Ashurst s
More informationThe Interaction of Canadian and US Economic Sanctions Against Iran and Other Countries
The Interaction of Canadian and US Economic Sanctions Against Iran and Other Countries John W. Boscariol June 14, 2016 Growing Impact of Canadian Trade Controls 1 what s driving this? since 9/11, new emphasis
More informationSenate Adopts New Sanctions Targeting Russia and Iran
Senate Adopts New Sanctions Targeting Russia and Iran June 16, 2017 On June 15, 2017, the United States Senate adopted S.722, incorporating the Countering Russian Influence in Europe and Eurasia Act of
More informationDancing Around Landmines: Hot Topics in U.S. and Canadian Sanctions. Momentum Events Webinar November 20, 2014
Dancing Around Landmines: Hot Topics in U.S. and Canadian Sanctions Momentum Events Webinar November 20, 2014 Who we are Daniel Chapman Chief Compliance Officer and Counsel, Parker Drilling Company dan.chapman@parkerdrilling.com
More informationB R E T T O N W OODS R E S E A R C H, L L C
War in Europe: A Market Perspective May 1, 2014 Executive Summary: Amid the unrest in Ukraine and growing tensions between Russia and the West, BWR reviews numerous episodes of geopolitical turbulence
More informationUkraine s Economy Since Independence and Current Situation
Ukraine s Economy Since Independence and Current Situation Dr. Edilberto Segura SigmaBleyzer - The Bleyzer Foundation January 2016 v5 1 W H E R E O P P O R T U N I T I E S E M E R G E Economic Performance
More informationPUBLIC LAW AUG. 2, 2017
131 STAT. 911 (2) by redesignating subsection (d) as subsection (e); (3) in subsection (c), by striking The President and inserting except as provided in subsection (d), the President ; and (4) by inserting
More informationSanctions. Sanctions Spotlight. Kerri-Ann Bent
Sanctions Sanctions Spotlight Kerri-Ann Bent Sanctions Overview Sanctions are restrictions on Economic and Business activity related to certain countries, individuals, Entities, industries or types of
More informationUkraine s Financial and Political Crisis. Anders Åslund Senior Fellow Peterson Institute for International Economics, Washington, DC
Ukraine s Financial and Political Crisis Anders Åslund Senior Fellow Peterson Institute for International Economics, Washington, DC May, 2009 Theses 1. Democracy, but constitutional reform needed 2. Hard
More informationRussian automotive market update: what would be the real cost of sanctions?
Russian automotive market update: what would be the real cost of sanctions? Moscow/Munich, September 2014 Amy Walters / Fotolia Management summary > With 12% decline in the first eight months of 2014,
More informationU.S. Government Takes Steps Toward Implementation of Sanctions on Russia
WHITE PAPER November 2017 U.S. Government Takes Steps Toward Implementation of Sanctions on Russia The United States has taken significant steps toward fully implementing the sanctions imposed on Russia
More informationThe deep freeze: the growing impact of sanctions on Jersey
JERSEY GUERNSEY LONDON BVI SINGAPORE JERSEY BRIEFING January 2015 The deep freeze: the growing impact of sanctions on Jersey "In recent times there has been a marked increase in the use of co-ordinated
More informationEU-US FOREIGN POLICY RELATIONS
TRANSATLANTIC RELATIONS: USA AND CANADA The EU, US and Canada share the values of democracy, human rights, and economic and political freedom, and overlapping foreign policy and security concerns. The
More informationU.S. and EU Sanctions on Iran and Russia For Le Cercle De la Compliance Beth Peters Lourdes Catrain Andrew Keller Aline Doussin.
U.S. and EU Sanctions on Iran and Russia For Le Cercle De la Compliance Beth Peters Lourdes Catrain Andrew Keller Aline Doussin May 31, 2018 Agenda U.S. Sanctions Programs U.S. Sanctions: Considerations
More informationHorizon scanner Financial Crime and Cyber-security RISK RATING. Potential impact
Horizon scanner Financial Crime and Cyber-security RISK RATING Potential impact The Financial Action Task Force (FATF) UK mutual evaluation 2018 FATF conducts reviews of each member on an on-going basis
More informationAnti-corruption and compliance in Russia
Anti-corruption and compliance in Russia Alex Stolarsky Rechtsanwalt Director Legal, Compliance & Tax, Member of the Board 8 October, 2018 - CHAMBER OF COMMERCE AND INDUSTRY OF THE RUSSIAN FEDERATION Agenda
More informationPayments and E-commerce Report Eastern Europe & the Commonwealth of Independent States EE/CIS
s and E-commerce Report Eastern Europe & the Commonwealth of Independent States Dear reader, Welcome to the PPRO Regional s and E-commerce report for Eastern Europe and the CIS (Commonwealth of Independent
More informationSPECIALISTS IN ACTIVE MANAGEMENT OF ETF PORTFOLIOS. BRIC Countries: How Are They Doing Today? Part II - Russia
Innealta C A P I T A L SPECIALISTS IN ACTIVE MANAGEMENT OF ETF PORTFOLIOS BRIC Countries: How Are They Doing Today? Part II - Russia Key Takeaways: Growth: Russia s economy is back on track after a recession
More informationU.S. Trade Controls: Key Compliance Challenges
U.S. Trade Controls: Key Compliance Challenges Prepared for: Presented By: Peter Flanagan and John Pisa-Relli, Accenture October 16, 2017 1 What Are Trade Controls? Export controls: Restrictions on the
More informationquick REFERENCE GUIDE TO SANCTIONS lists IN CANADA
quick REFERENCE GUIDE TO SANCTIONS lists IN CANADA The AML Shop has compiled this quick reference guide setting out the sanctions lists against which financial service companies are generally required
More informationTrade, sanctions, and economic issues in EU- Russian Relations
Trade, sanctions, and economic issues in EU- Russian Relations Presented by Crina Viju Carleton University Presentation prepared for the Jean Monnet Chair EUREAST Workshop: The European Union and Russia:
More informationCOMMISSION FREQUENTLY ASKED QUESTIONS ON EU RESTRICTIVE MEASURES IN SYRIA
Brussels, 1 st September 2017 Commission Notice COMMISSION FREQUENTLY ASKED QUESTIONS ON EU RESTRICTIVE MEASURES IN SYRIA Service for Foreign Policy Instruments COMMISSION FREQUENTLY ASKED QUESTIONS ON
More informationU.S. Sanctions Against Russians, Ukrainian Separatists and Iran What it Means For Insurers OFAC Compliance Programs
Westlaw Journal insurance coverage Litigation News and Analysis Legislation Regulation Expert Commentary VOLUME 24, issue 34 / may 30, 2014 Expert Analysis U.S. Sanctions Against Russians, Ukrainian Separatists
More informationThe Real Oligarchs of Donetsk
The Real Oligarchs of Donetsk TRINAT Akhmetov is the richest, most powerful oligarch in Ukraine. He has significant assets in Donetsk region where ousted president Viktor Yanukovych was governor from 1997
More informationDeutsche Bank AFC/ Sanctions. TECC London 2015 W2 - Sanctions April 23, 2015
AFC/ Sanctions TECC Lonn 2015 W2 - Sanctions April 23, 2015 Agenda 1 2 Sanctions Update Frame within the Frameworks a b c The need for a policy Discussion topics related to Sectoral Sanctions Other discussion
More informationHOW SHOULD CHINESE COMPANIES FACE INCREASED US ENFORCEMENT RISK FROM THEIR GLOBAL BUSINESS OPERATIONS?
Also in this section: 82 Overview of Chinese investment in Japan 84 Fictitious selfemployment in Switzerland COMPLIANCE ALERTS HOW SHOULD CHINESE COMPANIES FACE INCREASED US ENFORCEMENT RISK FROM THEIR
More informationGlobal Compliance Issues. Alan Gourley Michael Koebele Gareth Austin Adelicia Cliffe
Global Compliance Issues Alan Gourley Michael Koebele Gareth Austin Adelicia Cliffe Global Compliance Issues What you need to know about EU export controls for dual use items: The new EU Regulation 428/2009
More informationEconomic Sanctions: Canada s s New Compliance Minefield. John W. Boscariol
Economic Sanctions: Canada s s New Compliance Minefield John W. Boscariol jboscariol@mccarthy.ca June 13, 2011 Toronto i.e. Canada Canadian & U.S. Export Controls Workshop Growing Impact of Canadian Trade
More informationForbidden Compliance: The Application of EU and Canadian Anti-Boycott and Blocking Measures to U.S. Economic Sanctions and Export Controls
Forbidden Compliance: The Application of EU and Canadian Anti-Boycott and Blocking Measures to U.S. Economic Sanctions and Export Controls John W. Boscariol January 29, 2015 John W. Boscariol, McCarthy
More informationNEW US SANCTIONS AGAINST RUSSIA SANCTIONS AGAINST RUSSIA. HOW IS SWEDISH TRADE WITH RUSSIA AFFECTED? What is new?
NEW US SANCTIONS SANCTIONS AGAINST RUSSIA AGAINST RUSSIA HOW IS SWEDISH TRADE WITH RUSSIA AFFECTED? What is new? BUSINESS SWEDEN 2016 In August 2017, the US Congress has introduced new sanctions against
More informationSanctions Risk Management Symposium
Sanctions Risk Management Symposium September 18, 2017 1:30 PM 2:30 PM Navigating Increasingly Complex Sanctions Regimes Against Iran, Russia and Cuba: Hot Button Issues Elika Eftekhari Director of Trade
More informationМодели, методы, алгоритмы и программные средства в экономике и природопользовании
УДК 339.9 Ismaila Bojang, graduate student, department of Systems Analysis and Decision Making Ural Federal University named after the first President of Russia Boris Yeltsin Ekaterinburg, Russia James
More informationUPDATE ON US AND EU RUSSIA SANCTIONS ENERGY SECTOR FOCUS
UPDATE ON US AND EU RUSSIA SANCTIONS ENERGY SECTOR FOCUS as of 8 April 2015 2015 Morgan, Lewis & Bockius LLP Jon Hines, Partner Moscow Office Bruce Johnston, Partner London Office Margaret Gatti, Partner
More informationIran Sanctions Relief: Opportunities and Challenges for US and EU Financial Institutions
Iran Sanctions Relief: Opportunities and Challenges for US and EU Financial Institutions 8 October 2015 Although US and EU sanctions targeting Iran are not likely to be lifted before early 2016, there
More informationSills Egsgard LLP Bulletin: Corporate Social Responsibility and Corruption: Fulfilling CSR goals without violating anti-corruption laws
Sills Egsgard LLP Bulletin: Corporate Social Responsibility and Corruption: Fulfilling CSR goals without violating anti-corruption laws Corporate social responsibility ( CSR ) is increasingly important
More informationEU and US Sanctions. Summary of norms and Application Guidelines for Russia. AEB Legal Committee, supported by Baker&McKenzie CIS, Limited June 2014
Ref. Ares(2016)2381712-23/05/2016 EU and US Sanctions Summary of norms and Application Guidelines for Russia AEB Legal Committee, supported by Baker&McKenzie CIS, Limited June 2014 EU Sanctions 2 INTRODUCTION
More informationTHE AMERICAN CLUB SO YOU RE THINKING OF GOING WHERE? THE SHIPOWNER S GUIDE TO SANCTIONS PIRAEUS JUNE 9, 2011
THE AMERICAN CLUB SO YOU RE THINKING OF GOING WHERE? THE SHIPOWNER S GUIDE TO SANCTIONS PIRAEUS JUNE 9, 2011 1 Rule no. 1: Don t do business with this man 2 Sanctions : What are they? Trade and economic
More informationEvolving U.S. Economic Sanctions and their Legal Implications Cuba, Iran, Russia and Burma
Evolving U.S. Economic Sanctions and their Legal Implications Cuba, Iran, Russia and Burma Christopher R. Wall July 2015 Pillsbury Winthrop Shaw Pittman LLP U.S. Economic Sanctions - Overview Administered
More informationResolution 66/41. National Legislation on transfer of arms, military equipment and dual-use goods and technology. Ireland
Resolution 66/41 National Legislation on transfer of arms, military equipment and dual-use goods and technology Ireland 2013 Regulatory Environment The Irish legal system for the transfer of arms, military
More informationFİNANSBANK A.Ş. US$1,500,000,000 Global Medium Term Note Program
FIRST SUPPLEMENT dated April 2, 2014 to the Base Prospectus dated February 5, 2014 FİNANSBANK A.Ş. US$1,500,000,000 Global Medium Term Note Program This supplement (this Supplement ) is supplemental to,
More informationPublic Opinion Survey Residents of Ukraine
Public Opinion Survey Residents of Ukraine July 16-30, 2015 International Republican Institute Detailed Methodology The survey was conducted by Rating Group Ukraine on behalf of the International Republican
More informationForeign Corrupt Practices Act. 15 February 2018
Foreign Corrupt Practices Act 15 February 2018 Introduction The Foreign Corrupt Practices Act ( FCPA ), codified at 15 U.S.C. 78dd-1, et seq., has two separate parts. The antibribery provisions prohibit
More informationUkraine, Russia and the impacts of sanctions on IFCs
11 March 2014 Ukraine, Russia and the impacts of sanctions on IFCs Susannah Cogman, Herbert Smith Freehills (London) Zachary S. Brez, Ropes & Gray (New York) Aki Corsoni-Husain, Harneys (Cyprus & BVI)
More informationANNEX ANNEX. to the COMMISSION DELEGATED REGULATION (EU) /...
EUROPEAN COMMISSION Brussels, 6.6.2018 C(2018) 3572 final ANNEX ANNEX to the COMMISSION DELEGATED REGULATION (EU) /... amending the Annex to Council Regulation (EC) No 2271/96 of 22 November 1996 protecting
More informationAct 3 Anti-Money Laundering (Amendment) Act 2017
ACTS SUPPLEMENT No. 3 ACTS SUPPLEMENT 26th May, 2017. to The Uganda Gazette No. 30, Volume CX, dated 26th May, 2017. Printed by UPPC, Entebbe, by Order of the Government. Act 3 Anti-Money Laundering (Amendment)
More informationOfficial Journal of the European Union
12.9.2014 L 271/3 COUNCIL REGULATION (EU) No 960/2014 of 8 September 2014 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia's actions destabilising the situation in
More informationEU-Ukraine Intellectual Property Rights (IPR) Dialogue 2017
14B rue de la Science, 1040 Brussels, Belgium Tel: +32 2 880 3720 Fax: +32 2 808 8464 inta.org EU-Ukraine Intellectual Property Rights (IPR) Dialogue 2017 Please find below INTA s comments based on input
More informationEp. 4: Sanctions and Transactions
OnAir with Akin Gump Ep. 4: Sanctions and Transactions October 18, 2018 Hello, and welcome to OnAir with Akin Gump. I m your host, Jose Garriga. In a recent episode, three of Akin Gump s international
More informationJuly 17, 2014 SANCTIONS INTELLIGENCE. GENNADY TIMCHENKO & VOLGA GROUP adapting BUSINESS FOLLOWING U.S. & Canadian sanctions
July 17, 2014 SANCTIONS INTELLIGENCE UPDATE GENNADY TIMCHENKO & VOLGA GROUP adapting BUSINESS FOLLOWING U.S. & Canadian sanctions Overview In March and April, the US government sanctioned Russian businessman
More informationUkraine (Sovereignty and Territorial Integrity)
Financial Sanctions Notice 18.03.2014 Ukraine (Sovereignty and Territorial Integrity) Introduction 1. On 17 March 2014 the of the European Union imposed financial sanctions, against persons responsible
More informationNatasha Chichilnisky-Heal Yale University
A New Institutional Model for Eurasian Energy Governance Natasha Chichilnisky-Heal Yale University "Extractive Resources and Global Governance: Distributive Justice and Institutions" Yale University October
More information(Non-legislative acts) REGULATIONS
7.8.2018 L 199 I/1 II (Non-legislative acts) REGULATIONS COMMISSION DELEGATED REGULATION (EU) 2018/1100 of 6 June 2018 amending the Annex to Council Regulation (EC) No 2271/96 protecting against the effects
More informationUkraine s Crumbling Economy
January 14, 2019 By Ekaterina Zolotova Ukraine s Crumbling Economy The country s persistent economic strife is veering toward crisis. Ukraine is in internal disarray. Driving the disarray is its deteriorating
More informationNew Sanctions for Russian Currency Control Violations: a Tempest in a Teapot or Pandora s Box of Liability? April 2013
New Sanctions for Russian Currency Control Violations: a Tempest in a Teapot or Pandora s Box of Liability? April 2013 In February 2013, changes to the RF Code of Administrative Offenses took effect. They
More informationUkraine: Current Political and Economic Situation
Ukraine: Current Political and Economic Situation Dr. Edilberto Segura Partner and Chief Economist, SigmaBleyzer President of the Board, The Bleyzer Foundation June 2014 1 A Dramatic Change in Political
More informationTABLE OF CONTENTS PART I PETRONAS ECONOMIC SANCTIONS AND EXPORT CONTROL POLICY STATEMENT...4
1 TABLE OF CONTENTS PART I PETRONAS ECONOMIC SANCTIONS AND EXPORT CONTROL POLICY STATEMENT...4 PART II PETRONAS ECONOMIC SANCTIONS AND EXPORT CONTROL GUIDELINES..5-12 1. SCOPE OF APPLICATION.6 2. GUIDING
More informationFlying in crises areas Insurance law implications
Flying in crises areas Insurance law implications 3rd Aviation Law Afternoon Workshop Lars Gerspacher 23 June 2015 Synopsis Ukraine as an example of a crisis area How do insurers grapple with crisis areas?
More informationRussian counter-sanctions
Russian counter-sanctions Review of 2018 and outlook for 2019 / Executive summary January 2019 Introduction In 2018, the Russian Federation for the first time took comprehensive counter-measures to respond
More informationSyria Sanctions 16 December 2014
Syria Sanctions 16 December 2014 SYRIA : EUROPEAN UNION WHO DO THE EU SANCTIONS APPLY TO? The EU sanctions regime applies 1 : a) within the territory of the EU, including its airspace; b) on board any
More informationPOLICIES AND PROCEDURES
Introduction This Policy is adopted by Paradigm to reinforce its commitment to full compliance with all laws of the United States pertaining to export controls and economic sanctions. This Policy revises
More informationCriminal Issues Arising in International Trade: Canada s Economic Sanctions
Criminal Issues Arising in International Trade: Canada s Economic Sanctions 20 th Transnational Crime Conference IBA Criminal Law Committee & IBA Business Crime Committee Lisbon, Portugal John W. Boscariol
More informationTRADE SANCTIONS MANUAL for Saferoad Group
TRADE SANCTIONS MANUAL for Saferoad Group TABLE OF CONTENT 1. Introduction to Trade Sanctions 5 2. Executive Summary 7 3. Identifying High-Risk Countries 8 4. Risk Mitigation in Dealings with Counterparties
More informationChapter 1 General Provisions
Strategic Goods Act 1 Passed 17 December 2003 (RT 2 I 2004, 2, 7), entered into force 5 February 2004, Chapter 1 General Provisions 1. Scope of application (1) This Act regulates: 1) the export of strategic
More informationFİNANSBANK A.Ş. US$1,500,000,000 Global Medium Term Note Program
SECOND SUPPLEMENT dated August 18, 2014 to the Base Prospectus dated February 5, 2014 FİNANSBANK A.Ş. US$1,500,000,000 Global Medium Term Note Program This supplement (this Supplement ) is supplemental
More informationWith many multi-million. Insights. Peace of mind. Negotiating the sanctions regulatory maze: Key jurisdictions to consider
Peace of mind Negotiating the sanctions regulatory maze: Key jurisdictions to consider Insights With many multi-million dollar lawsuites plaguing even the biggest global companies, understanding the regulatory
More informationFACULTY OF LAW. Business Organizations. Section 3. Jon Festinger, Q.C. TOTAL MARKS: 100
FACULTY OF LAW THE UNIVERSITY OF BRITISH COLUMBIA Page 1 of 8 HAS 3 PARTS. SUPPORT YOUR ANSWERS WITH REFERENCE TO MIGHT BE. RELEVANT CASE LAW AND/OR STATUTORY AUTHORITY WHERE DEFINITIVE CONCLUSION, THEN
More informationTHE WTO MOOT COURT 2015
THE WTO MOOT COURT 2015 Case In state Episodia there is an increasingly violent public fight about the future affiliation of this state to its neighbors. Two groups of the population are standing against
More informationOFAC Adds Rosneft and VEB Subsidiaries to SSI List, Designates Russian SDNs, Advises on Evasion
OFAC Adds Rosneft and VEB Subsidiaries to SSI List, Designates Russian SDNs, Advises on Edward Krauland, Meredith Rathbone, Anthony Rapa, and Bibek Pandey August 10, 2015. On July 30, 2015, OFAC added
More informationGazprom and Europe's gas problem
Gazprom and Europe's gas problem 21 Sept 2012 Summary The launch of the European Commission s expected market abuse investigation against Russia s Gazprom has raised temperatures between Brussels and Moscow.
More informationOctober Sanctions Guide. The Impact of Sanctions on Russia. Chris Weafer Senior Partner, Macro-Advisory Ltd
October 2017 Sanctions Guide The Impact of Sanctions on Russia Chris Weafer Senior Partner, Macro-Advisory Ltd cjw@macro-advisory.com 1 Summary Sanctions have created a great deal of uncertainty in the
More informationUK Tax Update: It s not all about Brexit!
August 2016 UK Tax Update: It s not all about Brexit! There has rightly been a great deal of attention paid to the UK s decision to leave the EU and what that may mean from a business (including tax) perspective.
More informationFinancial Sanctions Notice 26/03/2012
Financial Sanctions Notice 26/03/2012 Iran (nuclear proliferation) Council Regulation (EU) No 267/2012 This notice is issued in respect of the restrictive measures directed by the Council of the European
More informationMoody s Caa2 / S&P B- / Fitch B- 1 Economy: Agriculture 14%, Industry 27%, Services 60%
Ukraine Summary Moody s Caa2 / S&P B- / Fitch B- 1 Economy: Agriculture 14%, Industry 27%, Services 60% Ukraine is in a difficult economic, social, and political situation that has been exacerbated by
More informationUkraine Legal Provisions. International law firm Integrites. Complied by: Kiev, November 2015 GENERAL REMARKS
Ukraine Legal Provisions Complied by: International law firm Integrites Kiev, November 2015 GENERAL REMARKS On 27 June 2014, the EU-Ukraine Association Agreement was signed by the European Union Heads
More informationBREXIT UK VOTES TO LEAVE THE EUROPEAN UNION UK remains in the European Union - for now Implications for the Insurance Industry
CLIENT MEMORANDUM BREXIT UK VOTES TO LEAVE THE EUROPEAN UNION June 24, 2016 AUTHORS Nicholas Bugler Joseph D. Ferraro Andrew Tromans On 23 June the British electorate voted on the question of whether or
More informationTHE SIX-MINUTE Real Estate Lawyer 2017
TAB 2 THE SIX-MINUTE Real Estate Lawyer 2017 Proceeds of Crime (Money Laundering) and Terrorist Financing Act and Related Record-Keeping Candace Cooper Daoust Vukovich LLP November 21, 2017 Presented
More informationSanctions and End-Use Controls. Paul Whitfield-Jones Norton Rose Fulbright Julie Taylor Meggitt PLC
Sanctions and End-Use Controls Paul Whitfield-Jones Norton Rose Fulbright Julie Taylor Meggitt PLC Overview Sanctions in the UK Asset freezes Funds or assets belonging to or held, owned or controlled by
More informationRoyal United Services Institute July Osborne s Summer Surprise for Defence. Guaranteed Real-Terms Spending Increases
BRIEFING PAPER SDSR 2015: Hard Choices Ahead Royal United Services Institute July 2015 Osborne s Summer Surprise for Defence Guaranteed Real-Terms Spending Increases Malcolm Chalmers It was widely expected
More informationRC & EVOLVING US SANCTIONS: MAINTAINING COMPLIANCE. risk compliance RISK & COMPLIANCE MAGAZINE. risk & compliance REPRINTED FROM: OCT-DEC 2018 ISSUE
R E P R I N T RC & risk compliance & EVOLVING US SANCTIONS: MAINTAINING COMPLIANCE REPRINTED FROM: RISK & COMPLIANCE MAGAZINE OCT-DEC 2018 ISSUE RC & risk & compliance Visit the website to request a free
More informationSanctions listing to lifting
FEATURE SANCTIONS Sanctions listing to lifting The pariah status of sanctions list designation is prompting targeted parties to fight for removal, with some notable successes in the European Court of Justice.
More informationSOUTHWESTERN ENERGY COMPANY ANTI-CORRUPTION COMPLIANCE POLICY
SOUTHWESTERN ENERGY COMPANY ANTI-CORRUPTION COMPLIANCE POLICY I. Introduction At Southwestern Energy Company, we and our controlled subsidiaries and joint ventures (collectively, SWN or the Company ) build
More informationKathryn Gordon tel: ); Joachim Pohl tel: )
For Official Use For Official Use Organisation de Coopération et de Développement Économiques Organisation for Economic Co-operation and Development 19-Sep-2012 English - Or. English DIRECTORATE FOR FINANCIAL
More informationBetween The GOVERNMENT OF CANADA. and the LITTLE SALMON/CARMACKS FIRST NATIONS
TAX COLLECTION AND TAX SHARING AGREEMENT Between The GOVERNMENT OF CANADA and the LITTLE SALMON/CARMACKS FIRST NATIONS MEMORANDUM OF AGREEMENT DATED AS OF,19 BETWEEN: THE GOVERNMENT OF CANADA ("Canada")
More informationThe Republic of Moldova: An Assessment of Macroeconomic Policies and Recommendations
The Republic of Moldova: An Assessment of Macroeconomic Policies 1998-2001 and Recommendations Report Prepared for Public Policy 556: Macroeconomics Professor Kathryn Dominguez Prepared by Shannon Hill,
More informationTestimony Ukraine, Moldova, the European Union, and US Interests
Testimony Ukraine, Moldova, the European Union, and US Interests Anders Åslund, Senior Fellow, Peterson Institute for International Economics Testimony before the US Senate Committee on Foreign Relations,
More informationOlga Pogarska, Edilberto L. Segura
June 214 Olga Pogarska, Edilberto L. Segura Political unrest shifted to eastern Ukraine over April-May 214 as armed pro-russian rebels took control over large territories in Luhansk and Donetsk oblasts,
More informationDefining OFAC Property Interests Beyond The 50% Rule
Portfolio Media. Inc. 111 West 19 th Street, 5th Floor New York, NY 10011 www.law360.com Phone: +1 646 783 7100 Fax: +1 646 783 7161 customerservice@law360.com Defining OFAC Property Interests Beyond The
More information