US expands sanctions against Russia
Reed Smith LLP has provided the below informaton about expanded sanctions against Russia. Notably, these new sanctions have implications for non-U.S. persons and entities.
While non-U.S. persons generally are not subject to U.S. sanctions, they may now face secondary sanctions under Countering America’s Adversaries Through Sanctions Act (CAATSA) for engaging in “significant” transactions with designated Russian parties or entities blocked as a result of OFAC’s 50% Rule. Because OFAC’s designations now include a broader scope of Russian oligarchs, officials, and entities, non-U.S. companies and financial institutions will need to carefully consider the risk of secondary sanctions when dealing with Russian parties in the future.
In addition, OFAC’s recent action means that entities operating in key sectors of the Russian economy, such as energy, finance, defense, or oil, face a heightened risk of becoming designated in the future.
For comprehensive guidance regarding sanctions against Russia (and other countries) please see the Club’s website at https://www.swedishclub.com/loss-prevention/legal/sanctions/
Member Alert is published by The Swedish Club as a service to members. While the information is believed correct, the Club cannot assume responsibility for completeness or accuracy.