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Business In Russia In Times of Crisis: Executive Orders 13660, 13661 and 13662 – New Additions to SDN List [June 20, 2014]

by | Jun 25, 2014 | Blog, Publications

On March 6, 2014, the President of the United States issued Executive Order (“E.O. 13660”) authorizing sanctions on individuals and entities responsible for Russian activities related to Ukraine.  On June 20, 2014 the Office of Foreign Asset Control (“OFAC”) added to the SDN List, seven Ukraine separatists accused of stoking violence.
Marks & Sokolov attorneys provide advice on structuring contracts and protecting interests in the face of possible additional economic sanctions on Russia; and counsel companies interacting with sanctions targets. Any U.S. company doing or planning to do business with Russian companies should seek guidance regarding compliance with these Executive Orders which apply to U.S. companies, as well as foreign companies which they control, and all U.S. citizens.  Marks & Sokolov attorneys can assist with compliance by providing:
–          A review of contracts with Russian parties, including an examination of Russian contract parties and their beneficial owners;
–          Determination whether the sanctions apply and prohibit contract performance;
–          Advice regarding potential liability to contract parties and the US Department of the Treasury,
–          Advice regarding notification of termination of contracts and the disposition of deposits;
–          Advice about possible defenses against liability such as justified non-performance due to force majeure circumstances and regulatory prohibition.
Marks & Sokolov, LLC has extensive experience representing multinational clients in the United States and Russia.  For more information please contact, in the United States:  Bruce Marks (marks@mslegal.com) or Thomas Sullivan (tsullivan@mslegal.com) at (215) 569-8901; or in Russia, Sergey Sokolov (ssokolov@mslegal.com) or Derek Bloom (dbloom@mslegal.com) at +7-495-626-0606.On March 6, 2014, the President of the United States issued Executive Order (“E.O. 13660”) authorizing sanctions on individuals and entities responsible for Russian activities related to Ukraine.  On June 20, 2014 the Office of Foreign Asset Control (“OFAC”) added to the SDN List, seven Ukraine separatists accused of stoking violence.
Marks & Sokolov attorneys provide advice on structuring contracts and protecting interests in the face of possible additional economic sanctions on Russia; and counsel companies interacting with sanctions targets. Any U.S. company doing or planning to do business with Russian companies should seek guidance regarding compliance with these Executive Orders which apply to U.S. companies, as well as foreign companies which they control, and all U.S. citizens.  Marks & Sokolov attorneys can assist with compliance by providing:
–          A review of contracts with Russian parties, including an examination of Russian contract parties and their beneficial owners;
–          Determination whether the sanctions apply and prohibit contract performance;
–          Advice regarding potential liability to contract parties and the US Department of the Treasury,
–          Advice regarding notification of termination of contracts and the disposition of deposits;
–          Advice about possible defenses against liability such as justified non-performance due to force majeure circumstances and regulatory prohibition.
Marks & Sokolov, LLC has extensive experience representing multinational clients in the United States and Russia.  For more information please contact, in the United States:  Bruce Marks (marks@mslegal.com) or Thomas Sullivan (tsullivan@mslegal.com) at (215) 569-8901; or in Russia, Sergey Sokolov (ssokolov@mslegal.com) or Derek Bloom (dbloom@mslegal.com) at +7-495-626-0606.