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Sanctions on Russian Securities Infrastructure Create Additional Hurdles to Divesting from Russia
The Russian financial services sector remains a key target of U.S., UK, and EU sanctions. As discussed below, a number of recent such sanctions against Russia and countermeasures by the Russian government have further complicated efforts for investors seeking to divest listed securities from Russia. As mentioned in our previous alert, on November 21, 2024,...
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2024 Brought Heightened Awareness of Political Speech in the Workplace
Boris Godunov is an opera based on the historical events surrounding the rise and fall of the Russian Tsar of the same name. Written by Russian composer Modest Mussorgsky, the opera is set in the early 17th century, a time of great turmoil in Russia. Exploring themes of legitimacy, power, and the burden of leadership,...
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Russian Countermeasures: The Governmental Commission Tightens Conditions for Exits by Investors From Unfriendly Jurisdictions
As anticipated by recent media coverage, the Governmental Commission for Control over Foreign Investments (the “Governmental Commission”) published its October 15, 2024 decision tightening conditions for exits by investors from “unfriendly” jurisdictions (i.e., those that have imposed sanctions against Russia) (the “Decision”). Prior to the Decision, the Governmental Commission had already imposed various conditions when...
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G7 Issues New Recommendations to Prevent Circumvention of Sanctions Against Russia
The primary objective of this guidance is to ensure industry compliance with export controls and help businesses identify risks associated with circumvention of export restrictions directed against the Russian military-industrial complex. The joint guidance identifies the following priority areas: (i)products posing an increased risk of reexport to Russia; (ii) red flag indicators of potential export...
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New Ukrainian Law Targets Ukrainian Orthodox Church for Ties to Russia
Forum 18 reports that Ukraine’s Law No. 3894-IX (full text in Ukrainian) signed into law on August 24 came into force on Monday. According to the report: The Law bans the Russian Orthodox Church – Moscow Patriarchate (ROC) for its justification and proactive support of Russia’s invasion of Ukraine. The Law identifies the ROC as a...
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OFAC, State Department, and BIS Expand Russian/Belarusian Sanctions
On August 23rd, 2024, the U.S. Treasury’s Office of Foreign Assets Control (OFAC), the U.S. Department of State (State), and the Commerce Department’s Bureau of Industry and Security (BIS) acted against Russia’s international supply chains. OFAC and State collectively sanctioned nearly 400 individuals and entities. Of note, this included a substantial focus on targeting non-Russian...
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BIS Issues New Guidance to Combat Russia Diversion Risks and Highlights Recent Enforcement Actions
Recently, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued new guidance to exporters intended to further assist BIS in its efforts to crack down on third-party diversion to Russia. Specifically, BIS’s recent guidance outlines the various mechanisms it has employed—outside of its usual public screening lists (i.e., the Unverified List, Entity...
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A New Gambit? DOL Independent Contractor Rule Still Facing Court Challenges
There are lots of strategies for winning a chess match. Most gambits are named for people, but some have funny names like the Alien Gambit, the Zilbermints Double Countergambit, and the Fried Liver Attack. At a chess tournament earlier this month in Makhachkala, Russia, one competitor tried a new strategy. She (allegedly) smeared mercury on...
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Convicted Russian Cybercriminals Part of Prisoner Swap
It is heartwarming that 16 prisoners, including innocent ex-Marine Paul Whelan and Wall Street Journal reporter Evan Gershkovich, have been freed from their wrongful imprisonment in Russia in exchange for 24 convicted Russian prisoners. What is disturbing is that innocent individuals wrongfully convicted are being used to bargain for convicted individuals, including cybercriminals. Krebs on...
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Privacy Tip #408 – Russian Cybercriminals Get 69% of Ransom Payments
Anecdotally, we know that cybercriminals hailing from Russia are a significant risk to U.S.-based and world companies and governmental entities. With two convicted Russian cybercriminals being released this week in the prisoner swap I was curious just how significant Russian cybercriminals play in cybercrime chaos. According to Bleeping Computer, “Russian-speaking threat actors accounted for at...