International Economic Compliance

Sanctions pressure is constantly rising, and so are the risks that come with it. These risks are seen in international transactions and foreign investments. They affect every transaction and hence, can and should be taken into consideration when drafting and implementing a business strategy.

Sanctions affect the rights and interests of Russian nationals and entities, including those who enter into international transactions, conduct foreign currency operations, travel abroad, employ foreign associates or managers, or have beneficiaries overseas.

It’s evident that sanctions risks arise not only from direct violations but indirectly, as well. They can include negligent actions, as well as those arising from attempts to circumvent sanctions.

Secondary sanctions have always been a feature of the U.S. sanctions programs, yet for many they became notable only when they were embedded into Russia-related sanctions legislation. The key feature of secondary sanctions is a transaction with an individual or an entity that violated restrictions imposed against a third party. Such violations may be found when delivering goods or rendering services.

Companies for which foreign components or goods are essential face a special risk. As these goods are under a special legal regime, their risks may have a criminal law component, as well.