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Summary of Crucial Details in the latest ART DE LEX Sanctions Newsletter

With Western sanctions still in place against Russia with respect to Crimea and Sevastopol, ART DE LEX has provided updated information in its 9 February Sanctions Newsletter about European and American actions as well as the Russian response.

On 29 January 2015, the European Union extended until September 2015 its current sanctions against Russia.  It also modified some of the sanctions and added more individuals to the restricted list.  The EU expanded the prohibitions to include all EU-based investments located in or providing goods and services to Crimea and Sevastopol, including financial transactions and tourism.  Contracts concluded before 20 December 2014 are exempt from the sanctions, although as of 21 March 2015, certain goods and services linked with agreements dated prior to 20 December 2014 will be prohibited.

On 9 December 2014, the American president, Barack Obama, issued an executive order forbidding American individuals and companies from conducting business, including investment and trade, in Crimea.  The president also froze all property in the US of individuals and legal entities from or linked to Crimea.  American firms and individuals may honor contracts with entities doing business in Crimea concluded before 20 December 2014 only until 1 February 2015.  The export of agricultural goods, medical supplies, and replacement parts to Crimea are permitted.  Furthermore, communication, including mail, now is permitted with Crimea.  Financial transactions may take place if they are not of a business nature and do not involve sanctioned individuals.

In reaction to EU and US sanctions, the State Duma passed a measure on 20 January 2015 that enables the General Prosecutor to designate certain foreign or international organizations operating in the Russian Federation that operate illegally as posing a threat to the defense of the state, public order, or public health. Such organizations may face restrictions on their operation, sanctions as terrorists or extremists, and prohibitions on disseminating printed or digital information.  They also may be faced with a series of fines, ranging from RUB 10,000 to 20,000, with stiffer penalties for repeat offenses. The legislation will bar individuals linked with restricted organizations from entering the Russian Federation. Russian citizens and legal entities may face fines for having engaged in transactions with restricted organizations.

The International Sanctions Group at ART DE LEX will help foreign companies adjust their projections and agreements with respect to their interests in Crimea or Sevastopol.  Additional information is available from Dmitry Magonya, Yaroslav Kulik, and Victor Fadeev at ART DE LEX.

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