Russia

Global sanctions guide

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  1. Does Russia have a sanctions regime in place?

Yes.

  1. Does Russia implement UN sanctions?

Yes. In accordance with Federal Law No. 281-FZ dated 22 December 2006 On Special Economic Measures, Russia implements UN sanctions with presidential d ecrees.

  1. Does Russia implement an autonomous sanctions regime?

Yes. Resolution of the Government of the Russian Federation No 778 dated 7 August 2014 (as amended) have imposed a ban on import of certain listed agricultural products, raw materials, foodstuffs from the United States of America, the European Union countries, Canada, Australia, Norway, Ukraine, Albania, Montenegro, Iceland, Liechtenstein. In addition Russia has introduced also travel bans against certain EU, American and Canadian politicians and military leaders from entering to Russia.

Certain limited restrictive trade measures against Turkey remain partially in force (eg quotas of import) as well as visa-free regime has not recovered yet.

  1. What is the nature of the sanctions regime in Russia?

Government Resolutions and corresponding presidential decrees on special economic measures, including sanctions based on UN Security Council resolutions, are implemented under Federal Law No. 281-FZ dated 22 December 2006.

Russia implements arms embargoes, export control, bans on imports of certain goods, travel bans on named individuals.

RF Government is also entitled to apply additional restrictive measures in the purposes of protection of RF payment balance and RF financial status.

  1. Does Russia maintain a list of sanctioned individuals and entities?

Yes. The names of individuals subject to travel ban have been named in media, but this list has not been made available.

  1. Are there any other lists related to sanctions?

Yes. The Federal Financial Monitoring Service maintains a list of organizations and individuals against whom there is evidence of participation in extremist activities or terrorism. The list can be accessed at http://fedsfm.ru/documents/terr-list

  1. Does Russia have a licensing or authorization system in place?

Yes. It is possible to obtain a license from the Russian Federation Federal Service for Technical and Export Control. In addition, the Russian Government can also issue a general license if it is satisfied that the applicant maintains an adequate internal export control program and also obtains a state accreditation certificate in respect of such a program. There is also the possibility to obtain a permit from the Russian Federation Export Control Commission for temporary exports of goods and technologies. Under this provision, a permanent transfer to a foreign party is not allowed and the permit holder is obliged to return the goods and technology back to Russia. Under the terms of a permit, the goods and technology exported must always be controlled by a Russian entity.

  1. What are the consequences for a breach of sanctions in Russia?

Chapter 16 of the Russian Federation Administrative Offences Code stipulates administrative fines for import of sanctioned products or if provided information or documents don’t comply with restrictive measures established by treaties of the Eurasian Economic Union, decisions of the Eurasian Economic Commission or regulations of the Russian Federation. The amount of fine varies from 5 000 RUB to 20 000 RUB for officials and from 50 000 RUB to 300 000 RUB for entities (along with possible confiscation of goods).

RF Government Resolution dated 31 July 2015 lays out procedures for the destruction of banned products.

A person found guilty of breaching article 189 of the Russian Federation Criminal Code (which deals with the illegal transfer of scientific and technical information to a foreign company or its representative for the purposes of development of arms, military equipment, weapons of mass destruction and their delivery) can be imprisoned for up to seven years, and fined up to 1,000,000 roubles or an amount equal to a salary/other income for a period of up to five years.

In the event of breach of export control regulations, the offending legal entity and/or its employees would be liable for administrative fines and/or criminal sanctions. Part 1, Article 14.20 of the Russian Federation Administrative Offences Code stipulates an administrative fine equal to the value of the subject of an administrative offence (along with possible confiscation of goods), for conducting foreign trade activities without a special license.

An organization can also be banned from engaging in certain types of foreign trade activities, if it is found that its actions have resulted in substantial damage to the political and economic interests of the Russian Federation or to Russia’s defence and state security.

  1. Who are the relevant regulators in Russia and what are their contact details?

The Russian Federation Export Control Commission

Key powers:

Granting permissions for foreign economic operations with non-controlled goods and technologies in cases stipulated by law;

Adoption of decisions on export of controlled goods and technologies without license;

Preparation of proposals for RF Government on forfeiture of right to perform certain types of foreign economic activities with respect to organizations that breach export control legislation.


The Russian Federal Service for Technical and Export Control

17, Staraya Basmannaya St.,
105175, Moscow.

Federal Financial Monitoring Service (Rosfinmonitoring),
Build.1, 39, Myasnitskaya St. 107450, Moscow.

T: (+7) 495 606 14 73, +7 495 627 33 97
E: postin@fstec.ru, info@fedsfm.ru


Ministry of Foreign Affairs

This Ministry has general powers on protection of Russian Federation interests, including issuance of lists of individuals who are not permitted to enter Russian Federation

32/34, Smolenskaya-Sennaya Sq.
119200, Moscow

T: (+7) 499 244 16 06
E: ministry@mid.ru


Ministry of Industry and Trade

Key powers:

Licensing for export and import of goods which require such licensing under Russian law (except for gas)

7, Kitaigorodskiy proezd
109074, Moscow

T: (+7) 495 539 21 87
E: info_admin@minprom.gov.ru

Contributor law firm

Anu Mattila, Eversheds Sutherland LLC 7 Gasheka St, Russian Federation, Moscow, 123056 Russia

T: (+7) 495 662 6434
F: (+7) 495 662 6436
Info.Russia@eversheds-sutherland.ru
www.eversheds-sutherland.com