Norton Rose Fulbright (LexBlog Russia)

On 28 February 2024, a statutory instrument (SI) – the Russia (Sanctions) (EU Exit) (Amendment) (Regulations) 2024 – was published on legislation.gov.uk. The SI amends the Russia (Sanctions) (EU Exit) Regulations 2019.   The SI was published alongside an explanatory memorandum, which notes that the legislation will ban the import of Russian diamonds processed in...

Introduction Following the unprecedented levels of sanctions activity in response to Russia’s invasion of Ukraine, which has resulted in companies dealing with the most significant and complex sanctions regimes across multiple jurisdictions, authorities in the US, UK and EU are now turning their attention to enforcement of those sanctions. Sanctions authorities have indicated that they...

On 6 September 2023, the FCA published a new webpage – Sanctions systems and controls: firms’ response to increased sanctions due to Russia’s invasion of Ukraine. The new webpage sets out key findings from the FCA’s assessments of sanctions systems and controls in financial services firms. It includes examples of good practice and areas for...

On 2 December 2022, HM Treasury published updated statutory guidance to assist in the implementation of, and compliance with the Russia (Sanctions) (EU Exit) Regulations 2019. The guidance has been updated to clarify the application of the prohibition on provision of technical assistance, financial services or funds related to G7 dependency and further goods.

On 2 September 2022, the European Securities and Markets Authority (ESMA) published its second trends, risks and vulnerabilities report of 2022. The report notes that Russia’s invasion of Ukraine against a backdrop of increasing inflation has profoundly impacted the risk environment of EU financial markets. For example, the report mentions that market conditions deteriorated as...

Canada’s Special Economics Measure Act (SEMA) provides the Government of Canada the authority to impose sanctions on foreign jurisdictions and persons. Since February 24, 2022, Canada has frequently amended the SEMA (Russia) Regulations (SOR/2014-58) (and other regulations enacted under SEMA), to list a significant number of individuals and entities as “designated persons”, thereby imposing a...

On 18 July 2022, the FCA issued its latest Handbook Notice (No. 101) describing the changes to the FCA Handbook and other material by the FCA Board under its legislative and other statutory powers on 23 June 2022 and 15 July 2022. On 23 June 2022, the FCA Board made changes to the Handbook in...

On 13 July 2022, the Financial Stability Board (FSB) published an interim report on exit strategies to support equitable recovery and address effects from COVID-19 and Russia’s invasion of Ukraine on the financial sector and how the FSB will address these issues going forward. It considers exit strategies in relation to financial stability and the...

On 7 July 2022, the European Securities and Markets Authority (ESMA) issued a public statement on prospectus supervision in the context of EU sanctions connected to Russia’s invasion of Ukraine. The statement alerts stakeholders to the European Commission’s FAQs, which cover the scope and implementation of EU sanctions and concerns whether there is sufficient legal...

This week, the European Commission is reportedly expected to present a legal proposal to make the evasion of sanctions an EU crime. This step will equip EU countries with a legal tool to confiscate frozen assets as part of the measures taken against Russia. It is estimated that to date around €30 billion in assets...

What have the financial services regulators been doing following the sanctions imposed on Russia? In the latest instalment of our Regulation Around the World series we cover some of the regulatory alerts that financial services regulators have issued in key jurisdictions. Our global updater focussing on the regulatory alerts is accompanied by further analysis in our...

February 24, 2022, Russian troops poured over the border into Ukraine, unleashing unimaginable human suffering and widespread destruction of property. Russia’s aggression also ignited negative consequences in the international economy that continue to increase and cascade throughout all sectors and corners of the globe. As companies and other entities struggle to navigate the broader macro-economi

The ink was not even dry on the update regarding Russia-related IP issues that we published last week, when we learned of two more major developments. The USPTO recently issued the following statement on engagement with Russia, the Eurasian Patent Organization and Belarus: Per guidance issued by the U.S. Department of State, the United States Patent and Trademark Office...

On 27 April 2022, there was published on the legislation.gov.uk website The Russia (Sanctions) (EU Exit) (Amendment) (No. 9) Regulations 2022. These Regulations amend the Russia (Sanctions) (EU Exit) Regulations 2019 (the 2019 Regulations) by adding new trade sanctions to Part 5 (Trade). These amendments will introduce new trade sanctions measures relating to internet services...

On 26 April 2022, the European Central Bank (ECB) issued FAQs on the Russia-Ukraine war and ECB Banking Supervision. The FAQs cover a number of issues including: The ECB’s role in the financial sanctions adopted by Russia and particular aspects it is looking at. What a bank should do if it is unsure about what...

On 20 April 2022, the Financial Stability Board (FSB) published a letter from its chair, Klaas Knot, to G20 Finance Ministers and Central Bank Governors ahead of their meeting on 20 April. The letter notes that the Russian invasion of Ukraine triggered large price fluctuations in global financial markets. Thus far, the global financial stability...

On 22 April 2022, the FCA published its findings following a multi-firm review into the financial crime controls at challenger banks. The review was conducted in 2021, predating the significant expansion of sanctions against Russia. Although the FCA’s focus on sanctions was limited, the main financial crime and money laundering controls it assessed equally apply...

On 7 March 2022 a decree of the Russian government took effect, announcing that compensation need not be paid for the unauthorised use of Russian patents, utility models and designs to rights holders connected with foreign countries committing “unfriendly acts” against Russian legal entities and individuals. In the case of patents, the citizenship of the...

On 31 March 2022, the Financial Stability Board (FSB) published its work programme for 2022. Priority areas for the FSB include: Supporting international cooperation and coordination on current financial stability issues. Against the backdrop of the Russia-Ukraine conflict and its economic impacts, the FSB is reinforcing its forward-looking monitoring to identify, assess and address new...

On 31 March 2022, the Financial Stability Board (FSB) published its work programme for 2022. Priority areas for the FSB include: Supporting international cooperation and coordination on current financial stability issues. Against the backdrop of the Russia-Ukraine conflict and its economic impacts, the FSB is reinforcing its forward-looking monitoring to identify, assess and address new...

On 24 March 2022, the Bank of England (BoE) published its latest Financial Policy Summary and Record. Among other things the BoE note that Russia’s invasion of Ukraine is increasing economic uncertainty and will increase pressure on borrowers. For example, sustained increases in energy prices resulting from the conflict are likely to put pressure on...

On 22 February 2022, the FCA published a new webpage concerning its expectations of firms in light of the UK’s sanctions on Russia. The key message from the FCA is that it expects firms to have established systems and controls to counter the risk that they might be used to further financial crime and this...

On 2 December, a new law was introduced in Russia to enable substantial administrative fines to be imposed on organizations and individuals that fail to comply with data localization requirements.  Both legal entities and responsible managers (e.g. the Data Protection Officer or the CEO) can be fined under the new regime. By way of recap,...

The world’s largest manufacturer of generic pharmaceuticals, Israeli-based Teva Pharmaceutical Industries Ltd. (“Teva International”), and certain of its global subsidiaries agreed to pay nearly US$520 million and enter into a Deferred Prosecution Agreement (“DPA”) to resolve allegations that the companies bribed government officials in Russia, Ukraine, and Mexico, in violation of the U.S....

Russia’s data protection authority, Roscomnadzor, has held a number of meetings with business associations to respond to the wave of questions that have arisen about the interpretation and application of Russia’s personal data localization law. The law, which enters into force on September 1, 2015, requires that an operator, while collecting personal data, ensures the recording,...

Russian President Vladimir Putin has signed into law the “right to be forgotten” legislation, which allows individuals in Russia to demand removal of a search engine’s links to personal information deemed irrelevant or inadequate. The law will go into effect on January 1, 2016. Some parts of the law are similar to a recent EU...