Wednesday 30th October 2024
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Comsure operates in:the UK, Jersey, Guernsey

Expanded US and EU Sanctions on Russian Persons = Implications for non-US companies as at April 29

  1. The US sanctions relating to Ukraine and Russia are primarily directed at US persons.
  2. Non-US persons are not directly required to comply with the sanctions, so long as the relevant transaction and parties involved do not have any US nexus.
  3. If US individuals or companies, or any person within the United States is involved in a transaction, or there is another sufficient nexus to the US, the US sanctions may be applicable even to non-US persons involved.
  4. In addition, certain prohibitions relating to the sanctioned companies are directly applicable to non-US persons as well as to US persons:

 

  • On April 28 the US expanded a practice it started with the April 11 sanctions on a Crimean entity, Chernomorneftegaz, by placing 13 of the 17 sanctioned companies on the Entity List. This is a list of prohibited parties under US export controls, separate from the SDN list administered by the US Treasury.

 

  • As a result, both US and non-US persons are directly prohibited, under US law, from certain transactions relating to these 13 companies involving any goods, equipment, software or technology of US origin.

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