Takeaways From Latest OFAC Guidance On Russia Sanctions
Law360, New York ( December 22, 2014, 11:34 AM EST) -- A key feature of the U.S. sanctions against Russian business interests has been the creation of the Sectoral Sanctions Identifications List (SSI List). U.S. companies must screen their Russian and Ukrainian business partners against the SSI List and the other U.S. prohibited persons lists. It is possible to do business with SSI-listed entities, as long as the particular transaction is not prohibited under the applicable directive or other applicable export control restrictions. Hence, it is not necessary to shun SSI-listed entities altogether. Given that some of the largest Russian banks and energy companies are on the SSI List, U.S. companies doing business in Russia must pay particular attention to what activities are prohibited with such entities. Below is a brief recap on the prohibitions imposed by the SSI List. It also includes key SSI-listed entities:...
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