On June 4, 2018, Russian President Vladimir Putin signed into law new counter-sanctions in response to U.S. sanctions imposed against Russia on April 6, 2018.  Under the new law, Putin may, among other things, sever ties with unfriendly countries and ban trade of goods with those countries.  The final version of the law stopped short of imposing criminal liability for compliance with U.S. and other foreign sanctions against Russian parties.  Companies are advised to consult with sanctions counsel before undertaking transactions in Russia (and certain other locations) that may be subject to OFAC primary and secondary sanctions.

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