FCPA Compliance Report - Matt Silverman on Potential Sanctions Against Russia

Thomas Fox - Compliance Evangelist
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In this episode of the FCPA Compliance Report, I am joined by Matt Silverman, Director of Trade Compliance at VIAVI. Part 1 of a special two-part podcast series looks at potential sanctions against Russia, Russian individuals, and Russian interests if Russia invades Ukraine. In this Part 1, we will consider the possible U.S. sanctions if Russia invades Ukraine? In Part 2, we will discuss what you can do to prepare for such an eventuality.

Potential sanctions we review in this episode See more +

In this episode of the FCPA Compliance Report, I am joined by Matt Silverman, Director of Trade Compliance at VIAVI. Part 1 of a special two-part podcast series looks at potential sanctions against Russia, Russian individuals, and Russian interests if Russia invades Ukraine. In this Part 1, we will consider the possible U.S. sanctions if Russia invades Ukraine? In Part 2, we will discuss what you can do to prepare for such an eventuality.

Potential sanctions we review in this episode include:

1. Impose a comprehensive or near-complete embargo of Russia.

2. Impose additional sectoral sanctions on specific Russian industries.

3. Prohibit exports of certain items or technology to Russia.

4. Designate Russian entities under the Foreign Direct Product Rule.

5. Add specific Russian entities or individuals to OFAC’s Specially Designated Nationals and Blocked Persons List (“SDN”).

6. Prohibit Russian entities from accessing the U.S. financial system/using U.S. dollars and/or sanctioning foreign banks that conduct transactions with sanctioned Russian entities.

7. Prohibit U.S. persons or entities from investing in Russian companies, requiring divestment, and/or sanctioning foreign entities that buy Russian government bonds.

8. Impose “secondary sanctions” on entities or individuals that conduct certain transactions with Russia.

9. Freeze Russian assets located in the U.S.

10. Ban U.S. financial assistance to Russian entities.

11. Withhold U.S. aid to any organizations that assist Russia.

12. Prohibit imports and/or impose high tariffs on specific Russian imports.

13. U.S. State-Level Sanctions: States may enact laws that prohibit business with, or require divestment of shares in, firms that conduct certain transactions with Russia.

Tune in to Compliance Podcast Network to learn more on Potential Sanctions Against Russia. See less -

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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