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Dec. 4, 2024

How Companies Can Protect Themselves From Secondary Sanctions Liability

In the wake of Russia’s 2022 actions in Ukraine, the U.S., U.K. and E.U. collectively initiated the most extensive and rapidly escalating sanctions regime in history. This unprecedented response saw the imposition of sweeping measures targeting key sectors of the Russian economy, high-profile individuals and critical state-owned enterprises. However, these extensive sanctions have not led to the intended outcome – by some measures, the Russian economy is thriving as the war in Ukraine grinds on. In this guest article, Martin De Luca, a partner at Boies Schiller, and Daria Pustilnik, a senior attorney at the firm, discuss how the U.S., U.K. and E.U. are attempting to increase pressure on Russia through secondary sanctions and the complications this may create for companies engaged in international trade. See this two-part series on the new Russia restrictions: “Agency Cooperation and Industry Focus” (Mar. 13, 2024), and “International Cooperation and Risk Mitigation” (Mar. 27, 2024).

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https://acuris.wistia.com/medias/wmb5vyeq2f

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Listen to our Fall Editorial Update for a discussion of recent enforcement actions; enforcement trends and policies; and top-of-mind issues, such as internal investigations and hotlines, all in under 15 minutes. Register here.

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