Jurisdiction(s):
United Kingdom

Russia sanctions divergence: implications for UK and EU touchpoints, corporate re‑entry, payment processing and designation risks amid potential US easing

Published on: 10 June 2025

Published by a Law360 reporter

Legal News

Article summary

John Bedford, a partner at Dechert LLP, observed that a number of companies have approached him to clarify whether they can trade in securities that have remained frozen or otherwise blocked since Russia’s invasion of Ukraine more than three years ago. Others are exploring if they should start laying groundwork now to re-enter the Russian market after a prolonged hiatus, mindful of the lengthy lead time needed to re-establish and stabilise operations. Any prospective geopolitical reset becomes more complex if the UK and EU decline to follow America’s lead, leaving advisers to grapple with applying divergent, and potentially conflicting, regimes. For multinational businesses, obtaining permission in a single jurisdiction is far from straightforward, as they risk breaching, or being seen to breach, rules in other territories. Bedford warned that, even where firms consider themselves subject only to US sanctions or believe subsidiaries can be carved out—potentially allowing dealings in Russia if America relaxes its measures—they must carry out rigorous analysis to ensure there are no UK or EU touchpoints, such as UK or EU nationals involved in any contemplated Russia-related business. Historically, companies have elevated global sanctions policies to align with American measures, whose terms have typically been most restrictive...

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