The European Commission has published Commission Guidance Note on the Implementation of Certain Provisions of Regulation (EU) No 833/2014, which provides guidance on the implementation of  restrictions imposed on the Russian financial sector pursuant to Council Regulation (EU) No 833/2014 as amended by Council Regulation (EU) No 960/2014 and Council Regulation (EU) No 1290/2014. The Guidance, conceived in a form of answers to certain questions that have been brought to the Commission’s attention, covers a broad range of topics relating to financial assistance, financial services, emergency funding, loans and access to capital markets. Among other things, it clarifies that deposits, including long-term deposits, with Russian banks subject to the restrictions are not prohibited.

On 11 December 2014, OFAC issued three new frequently asked questions (“FAQs”) that address issues under the United States’ sectoral sanctions on Russia. FAQ No. 419 clarifies questions regarding payment terms and prohibited extensions of credit under the sectoral sanctions.  FAQ Nos. 420 and 421 address issues related to the sectoral sanctions targeting Russia’s energy industry, clarifying the definitions of “production” and “Arctic offshore project,” respectively.

For further information on this topic, please see our Client Update “US and EU Continue to Expand Ukraine-related Sanctions and Clarify Sanctions Targeting Russian Companies”.