On 19 December, an article from Dechert LLP says that key issues to monitor in the near future include asset freezes against additional Russian persons, prohibitions on additional services being provided in Russia, clarifications on the handling of sanctioned Russian securities, and the significant potential for increased enforcement measures taken against violators. Indeed, it says, US officials have gone as far as describing sanctions as “the new FCPA”, signalling an expected “sea change” in the intensity with which sanctions violations will be prosecuted.
https://www.jdsupra.com/legalnews/russia-sanctions-where-are-we-now-and-3012852/
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