Russia/Ukraine Sectorial Focus: Best Practices when Working with EU Partners for Compliance with Sectorial Sanctions

April 24, 2017 4:10pm

Peter Chessick
Senior Counsel
OFAC, US Department of Treasury (Washington, DC)

David Mortlock
Partner
Willkie Farr & Gallagher LLP (Washington, DC)

John B. Reynolds lll
Partner
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