As a response to the Russian invasion of Ukraine starting in late February 2022, Australia, the European Union, Japan, the United Kingdom, the United States, and many other countries have progressively imposed increasingly significant sanctions and controls relating to Russia and Belarus. These have included targeted sanctions on institutions, state-owned enterprises and political elites, restrictions on debt and equity instruments as well as a broad range of other financial and investment restrictions, and banning virtually all activities involving the Russian-recognized "breakaway" regions of eastern Ukraine. Several countries have also imposed broad new import and export controls restricting access to a wide range of commodities, industrial products, software, technology, and luxury goods.
While the sanctions imposed against Russia and Belarus by these governments have many common features, there remain significant variations in the precise scope of the key regimes (raising particular issues for clients who already have or are seeking to follow a single, global policy approach).
Russia has retaliated with a number of growing countermeasures, such as targeted restrictions on specific products and services in Russia, and new rules aimed at foreign company decisions to wind down operations in Russia, including the possibility of treating such actions as "premeditated bankruptcy" punishable by significant civil and criminal penalties.
Jones Day's global sanctions team, and other practices, have been at the forefront of advising clients on the application of these complex and changing sanctions regimes to the operations of the businesses, the welfare of their employees, and the protection of their investments. In this document, we identify some of the key business impacts clients are facing.
The chart provides a high-level summary of key sanctions developments. These restrictions can be highly fact-specific in their application, and the rules and government guidance are changing rapidly. Please note that this chart is not an exhaustive account of all restrictions in place for these jurisdictions relating to Russia, Belarus, and Ukraine; rather, it seeks to highlight the ones we have been encountering the most in our ongoing advice to clients.
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