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To Russia, With Love
Imagine President Ronald Reagan saying, “Mr. Gorbachev, build that wall.” Crazy, right? And yet here we are, a president indulging in obvious lies while abandoning America’s allies and ending the isolation of Russia imposed for invading a neighboring sovereign nation, and his MAGA faithful swoon with adoration. In the course of a day, Trump has...
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Parting Shots by Biden Administration in the Form of Sweeping New Russia Sanctions
The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the U.S. Department of State issued new Russia sanctions on January 10th and 15th, 2025. January 10 Action In the January 10 action, OFAC and the State Department targeted entities involved in currently active Russian energy production and exports. Previously, the U.S....
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OFAC Expands Sanctions against Russian Energy Sector
On January 10, 2025, the U.S. Department of the Treasury, Office of Foreign Assets Control (“OFAC”) issued sweeping new sanctions targeting Russia’s energy sector, including the imposition of a new petroleum services ban, expanded secondary sanctions authority, and designations of certain Russian oil producers, insurance providers, and more than 180 so-called “shadow fleet” vessels. Until...
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EU Strengthens Sanctions Against Russia with 15th Package of Restrictive Measures
On December 16, 2024, the European Union (EU) adopted its 15th package of sanctions against Russia in response to its ongoing aggression toward Ukraine. The new measures target key sectors of Russia’s military-industrial complex, including the “shadow fleet” and companies that support this complex. Our colleagues at The Trade Practitioner cover this significant development in...
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The EU Strengthens Sanctions Against Russia with 15th Package of Restrictive Measures
On 16 December 2024, the European Union (EU) adopted its 15th package of sanctions against Russia in response to its ongoing aggression toward Ukraine. The new measures target key sectors of Russia’s military-industrial complex, including the “shadow fleet” and companies that support this complex. In a significant development, the EU has imposed fully-fledged sanctions –...
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A Flurry of Healthcare Sector Cybersecurity Regulatory Developments in 2024
2024 was a record year for cyberattacks in the healthcare sector. According to the Breach Portal maintained by the U.S. Department of Health and Human Services (“HHS”) Office of Civil Rights (“OCR”), to date this year, there have been more than 530 breaches of protected health information (“PHI”) affecting 500 or more individuals. 2024 also...
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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...