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Sanctions Take Aim At Russia’s Enablers as War Drags On


As Russia's war of aggression in Ukraine rounds out its first year, sanctions activity has slowed from a fire hose to a steady drip, with many attorneys now focused on preparing clients to navigate restrictions targeting Moscow's supporters abroad.


Top of mind for Blank Rome LLP partner Anthony Rapa among those precision tools were new regulations barring certain industries from providing services to Russia, export controls on industrial items as well as the restricted technology on the Commerce Control List, and, as of the end of the 2022, an international cap on the price companies could charge for Russian oil.

But with U.S. technology still slipping through the cracks and appearing in Russian offensives, the next wave of actions are likely to tackle Putin's supporters beyond his country's borders.

"The challenge now for companies that are engaged in cross-border trade, especially if they are dealing in industrial equipment or electronics or more sensitive items, is not whether they're going to do business with Russia or not. They've made those decisions already. But what can they do or what should they be doing to account for the possibility of the diversion of their products and their technology to Russia?" Rapa told Law360.

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"Sanctions Take Aim At Russia’s Enablers as War Drags On," by Jennifer Doherty was published in Law360 on February 23, 2023.