Russia/Ukraine Sectorial Focus: Best Practices when Working with EU Partners for Compliance with Sectorial Sanctions
OFAC, US Department of Treasury (Washington, DC)
Willkie Farr & Gallagher LLP (Washington, DC)
John B. Reynolds lll
David Polk & Wardwell LLP (Washington, DC)
- Question of what constitutes ‘debt’, given that three of four restrictions include debt restriction and collecting on debt
- Bond offerings: are these covered?
- Trying to purchase the sub of an SSI entity which would be non-compliant
- Directive 4 for Provision of Services for Projects: How Broad can those Services be and how broad is the financial exemption?
- Risks and challenges associated with Cyber Sanctions and Russia