The sanctions imposed on twenty leading Russian officials and businessmen with ties to Russian President Vladimir Putin and one financial institution, Bank Rossiya, by the United States on March 16 and 20, in response to Russian annexation of the Crimean peninsula in the Ukraine, have ramifications for western investors into Russia, including those with direct investment, in partnerships, alliances or joint ventures with Russian entities within or without Russia and companies with operating subsidiaries or other assets in Russia or in Russian-controlled institutions. Moreover, those ramifications may become more significant if the reach and severity of the sanctions is increased to core segments of the Russian economy, such as the oil and natural gas industries, as President Obama has threatened to do and as seems likely. It is not the purpose of this advisory to debate the public international law issues raised by Russia’s actions in Crimea, the legal bases of the U.S. sanctions regime or the sanctions’ likely macroeconomic effect. However, there are measures that western investors in Russia and business owners and partners of Russian enterprises can and should take to protect their investments and assets, both immediately and in the longer term, and those measures will be surveyed here. In general, a successful approach to navigating the Russia sanctions will require careful evaluation of exposure and anticipation of and response to issues likely to arise, rather than reaction after the fact.
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