Russia

Russia has imposed “counter-sanctions” in response to sanctions imposed on Russia by “unfriendly countries”, including import and export bans, targeted sanctions (asset freezes and travel bans), restrictions on transactions with foreign currency or foreign persons, and the exclusive jurisdiction of Russian courts over sanctions-related disputes.

Federal Law No. 127-FZ, 4 June 2018, “On Measures of Impact (Countermeasures) on the Unfriendly Actions of the United States of America and Other Foreign States” (the “Counter-Sanctions Law”) provides for a ban or restriction of:

• International cooperation with the designated entity;

• Import/export of materials to/from designated entity; and

• Provision of services by the designated entity for Russian state authorities or state-owned entities.

The type of measures which may be taken may be extended by presidential decree.  Targets of counter-sanctions are “unfriendly countries” (the USA and other countries that have imposed sanctions on Russia), and citizens and entities of unfriendly countries.

Federal Law No. 30-FZ, 4 March 2022, On Amendments to the Federal Law “On Measures against Persons Involved in Violations of Fundamental Human Rights and Freedoms and the Rights and Freedoms of Citizens of the Russian Federation” and Article 27 of the Federal Law “On the Procedure for Exit from and Entry to the Russian Federation” provides that targeted sanctions (travel bans and asset freezes) may be imposed on any foreign individuals (previously only US citizens).  Decree No. 252 (May 2022) provides that Russian entities are prohibited from entering into transactions with, performing obligations for, and exporting to “sanctioned persons”.