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Russian invasion of Ukraine – information for ENR clients

1 March 2022

The Russian Federation’s invasion of Ukraine on February 24th has triggered numerous events with crucial impacts on business involving those countries, their citizens, residents, international transactions and numerous people and entities worldwide. The United States, European Union and other countries have imposed sanctions on Russia and Russia-related businesses, individuals and transactions. Russia has retaliated by imposing its owned restrictions on businesses, transactions, assets and payments involving those related jurisdictions that imposed sanctions on Russia. The war has caused colossal migration of people from Russia and Ukraine to Europe and Israel. There is also an immense movement of businesses seeking relocation of their employees.

ENR is committed to providing its clients with full legal support during those turbulent times, including in the following areas:
• Information and news on sanctions imposed on Russia and related businesses and individuals.
• Russian restrictions involving cross-border payments and transactions with foreign residents from “non-friendly” jurisdictions.
• Business and assets of Russian residents and nationals abroad.
• Immigration, citizenship, repatriation and relocation, especially involving people leaving Ukraine and Russia.
• Impact of sanctions and restrictions on businesses, bank accounts, assets and transactions, including restructuring, relocation to other jurisdictions and opening new legal entities and bank accounts.
• Impact of Russian restrictions on local and foreign residents, including international businesses reducing or terminating operations in Russia.
• Impact of events on bank and other regulatory compliance and restrictions on cross-border capital flow.
• Support of crisis and change management.

It is important to mention that not all Russian nationals, residents and businesses are subject to sanctions, not all transactions with the Russian Federation are forbidden or restricted, and not all activities involving foreign residents are restricted in Russia:

(1) The US, EU, UK, Swiss and other personal sanctions have been imposed on a limited group of specific individuals and businesses, clearly identified in the publicly available documents; other sanctions target specific sectors of Russian business or type of transactions; the broadest type of sanctions target specific geographic areas of Russia-occupied Ukranian territory (like Crimea and DNR/LNR). Even those sanctions have exceptions and general licenses allowing to continue business relations (such as supply of food or medical equipment).

(2) Russian restrictions relate to specific jurisdictions that imposed sanctions on Russia and specific type of transactions (such as disposal of real estate in Russia or payments of debt and dividends).

(3) Not all bank transactions with Russia are banned altogether, however most of them undergo additional in-depth compliance.

We hope for prompt end of actual hostilities and casualties, and will continue supporting our clients during this period.