We are pleased to announce the strengthening of our sanctions practice with the addition of senior associate Elvira Khasanova.

Elvira Khasanova appeared as a guest expert on RBC Investments channel. She discussed the decision of the European Union Council to allow separate accounting of profits from frozen Russian assets for possible use for political purposes.

On March 13, the AmCham Russia conference "Key Compliance Results in 2023 and Expectations for 2024" took place, where KKMP Senior Associate Elvira Khasanova spoke on the factors affecting sanctions compliance in 2023 and expectations for 2024.

On March 14, the Pravo.ru conference "Legal Challenges and Opportunities in the Era of Sanctions" took place, where KKMP Senior Associate Elvira Khasanova participated in the session "Financial and Trade Restrictive Measures Regime. Doing Business in Global Isolation" speaking on sanctions regulation trends in 2024.

The year 2023 was marked by an intensification of sanctions pressure against Russia. According to some estimates, the number of personal sanctions imposed on Russian companies and individuals (“blocking sanctions”) alone is now approaching 20,000. Many countries have also started to develop legal mechanisms aimed at countering the sanctions circumvention. It is not easy to navigate such a large-scale and multifaceted sanctions regime and keep up with the details of how the sanctions are applied in practice. In this review, we present what we consider to be the key developments in the area of sanctions and their application in 2023, in the United States, the European Union and the United Kingdom, as well as likely trends in this area in 2024, which should be taken into account when doing business.

Prior to the Council of Europe's adoption, the Directive was approved by the European Parliament on March 12, 2024. It will enter into force 20 days after its publication in the Official Journal of the European Union. EU member states will have 1 year to transpose provisions of the Directive into their national legislation.

KKMP supported Kazan Legal Week 2024 held on May 22-24 by Pravo.ru and ANP ZENIT. KKMP Senior Associate Elvira Khasanova spoke on “Sanctions Compliance Trend in 2024: a necessity or a mechanism for adapting to an unstable reality?” during the “Prospects for Business Development in 2024” session.

We are delighted to invite you to an exclusive webinar titled “Right to an Attorney: Understanding U.S., EU and UK Sanctions on Legal Services to Russian Persons”, hosted in collaboration with our colleagues from Rimon (USA), RK Partners (Austria), Radcliffe Chambers (UK).

Elvira Khasanova, KKMP Senior Associate, has commented on possible developments for Russia if Trump comes to power.

On July 31, together with partners from Rimon (USA), RK Partners (Austria), Radcliffe Chambers (UK) we hosted a joint webinar “Right to an Attorney: Understanding U.S., EU and UK Sanctions on Legal Services to Russian Persons”.

We continue to monitor the status and development of initiatives related to confiscation of Russian assets in the US and EU. In spring, we published an overview of legal mechanisms and measures for the confiscation of Russian assets in these jurisdictions. Certain changes have occurred since then, which may affect the foreign assets of Russian persons.

At the end of April 2024, legislation ("H.R. 815 Act") was enacted in the U.S. providing for the extension of statute of limitations on violations of sanctions laws from 5 to 10 years.

On August 23, OFAC and the U.S. Department of State published an update to the U.S. sanctions list and several general licenses under the sanctions regime against Russia.

On October 30, the U.S. Treasury Department's Office of Foreign Assets Control (“OFAC”) and the U.S. Department of State added more than 400 companies and individuals to the sanctions lists. On the same day, the U.S. Department of Commerce's Bureau of Industry and Security (“BIS”) supplemented the Entity List (“Entity List”) comprising entities in violation of U.S. export controls.

In December 2022, certain European bar associations and lawyers, specifically, The Netherlands Bar of Brussels (Ordre néerlandais des avocats du barreau de Bruxelles) (Case No. T-797/22), The Bar Association of the Court of Paris (Ordre des avocats à la cour de Paris) (Case No. T-798/22) and ACE-Avocats (Case No. T-828/22) filed their claims with the General Court of the EU (“EU Court”) contending that the Court should repeal the prohibition on provision of legal advisory services imposed by “sectoral” Council Regulation (EU) No. 833/2014 (“Regulation 833/2014”) as part of the 8th package of sanctions. On 2 October 2024, the EU Court decided to uphold the prohibition making a few important conclusions that we include below.

On October 28, the UK Office of Financial Sanctions Implementation (OFSI) issued a new general license for the provision of legal services to designated persons of the Russian Federation and the Republic of Belarus.

Rossiyskaya Gazeta published the results of its large-scale annual research "Ranking of Lawyers and Law Firms". 13 KKMP lawyers were recognized as “top specialists” and “excellent specialists worth recommending by all means” in 13 nominations.

Today, the EU Council published the 15th package of sanctions against Russian companies and individuals. In addition to new listings of Russian entities and individuals, the European sanctions legislation has been supplemented to include two new rules that must now be taken into account when initiating proceedings in Russian courts.

In the few weeks before the inauguration of the new U.S. President, the SDN list saw several significant updates. On January 10 and January 15, as part of the Russia sanctions regime, OFAC and the U.S. Department of State designated numerous companies from the oil and gas, insurance and financial sectors adding them to the SDN list.

Elvira Khasanova, KKMP senior associate, commented for RBC on the outgoing Biden administration’s attempts to “protect” anti-Russian sanctions from Trump.