Wartime Sanctions

by time news

According to Anton Samokhvalov, a partner at the KIAP Law Office, when assessing the risks of a business with persons on the sanctions lists, it is important which list the sanctioned person is on. So, in the USA there are several lists. SDN contains a list of persons subject to personal sanctions, with such persons it is impossible to have any business, conclude any contracts, or even start negotiations. “For example, PSB and VEB were included in such a list. If a Russian company has placed depositary receipts on the US market, then, remaining a client of a bank located in the SDN, it risks being held liable in the US. At a minimum, this is a monetary fine, and at a maximum, criminal liability, depending on the circumstances of the violation and the company’s independent disclosure of the fact of the violation. There are also a number of non-SDN lists, including the SSI list, which are sectoral sanctions that prohibit only certain transactions. In such a list, for example, VTB and Sberbank. Being a client of such a bank is not a violation in itself, but receiving a “long” …

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