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Business In Russia In Times of Crisis: Do You Know With Whom You Do Business? – Executive Orders 13660 and 13661

by | Mar 21, 2014 | Blog, Publications

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On March 6, 2014, the President of the United States issued Executive Order (“E.O. 13660”) authorizing sanctions on individuals and entities responsible for Russian activities related to Ukraine.  On March 16, 2014, the President issued Executive Order (“E.O. 13661”) authorizing sanctions on, among others, officials of the Russian Government and any individual or entity that is owned or controlled by, that has acted for or on behalf of, or that has provided material or other support to, certain Russian government officials.  On March 20, 2014, the President expanded the scope of E.O. 13660 to authorize sanctions which prohibit doing business with certain Russian officials, business persons and a Russian bank.
Any U.S. company doing or planning to do business with Russian companies should seek guidance regarding compliance with these Executive Orders which apply to U.S. companies, as well as foreign companies which they control, and all U.S. citizens.  Marks & Sokolov attorneys can assist with compliance by providing:
–          A review of contracts with Russian parties, including an examination of Russian contract parties and their beneficial owners;
–          Determination whether the sanctions apply and prohibit contract performance;
–          Advice regarding potential liability to contract parties and the US Department of the Treasury,
–          Advice regarding notification of termination of contracts and the disposition of deposits;
–          Advice about possible defenses against liability such as justified non-performance due to force majeure circumstances and regulatory prohibition.
Marks & Sokolov, LLC has extensive experience representing multinational clients in the United States and Russia.  For more information please contact, in the United States:  Bruce Marks (marks@mslegal.com) or Thomas Sullivan (tsullivan@mslegal.com) at (215) 569-8901; or in Russia, Sergey Sokolov (ssokolov@mslegal.com) or Derek Bloom (dbloom@mslegal.com) at +7-495-626-0606.
Executive orderslogo transparent
On March 6, 2014, the President of the United States issued Executive Order (“E.O. 13660”) authorizing sanctions on individuals and entities responsible for Russian activities related to Ukraine.  On March 16, 2014, the President issued Executive Order (“E.O. 13661”) authorizing sanctions on, among others, officials of the Russian Government and any individual or entity that is owned or controlled by, that has acted for or on behalf of, or that has provided material or other support to, certain Russian government officials.  On March 20, 2014, the President expanded the scope of E.O. 13660 to authorize sanctions which prohibit doing business with certain Russian officials, business persons and a Russian bank.
Any U.S. company doing or planning to do business with Russian companies should seek guidance regarding compliance with these Executive Orders which apply to U.S. companies, as well as foreign companies which they control, and all U.S. citizens.  Marks & Sokolov attorneys can assist with compliance by providing:
–          A review of contracts with Russian parties, including an examination of Russian contract parties and their beneficial owners;
–          Determination whether the sanctions apply and prohibit contract performance;
–          Advice regarding potential liability to contract parties and the US Department of the Treasury,
–          Advice regarding notification of termination of contracts and the disposition of deposits;
–          Advice about possible defenses against liability such as justified non-performance due to force majeure circumstances and regulatory prohibition.
Marks & Sokolov, LLC has extensive experience representing multinational clients in the United States and Russia.  For more information please contact, in the United States:  Bruce Marks (marks@mslegal.com) or Thomas Sullivan (tsullivan@mslegal.com) at (215) 569-8901; or in Russia, Sergey Sokolov (ssokolov@mslegal.com) or Derek Bloom (dbloom@mslegal.com) at +7-495-626-0606.
Executive orders