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EU and UK sanctions: providing restricted services and software to Russian subsidiaries—licensing rules, Member State divergences (Germany, France, Italy) and UK practice

Published on: 04 July 2024

Published by a Law360 reporter
Legal News
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Article summary

Additionally, some EU nationals delivering services to their Russian subsidiaries will not need to secure a licence. By contrast, UK sanctions on Russia have never included the so‑called partner countries’ subsidiaries exemption, so UK businesses or UK nationals supplying business services to Russian entities have always had to seek a licence. For context, after the EU adopted its 12th sanctions package on 19 December 2023, the partner countries’ subsidiaries exemption was scheduled to be withdrawn over six months. Accordingly, from 20 June 2024, EU companies and EU nationals must obtain a licence from the competent authorities of the Member States to provide business services or software to their Russian subsidiaries. In this article, we analyse how the German, French, Italian and UK regimes are addressing this question.

Restricted services and software

From 30 September 2024, EU entities will be prohibited from supplying specified business services — including accounting, auditing, bookkeeping and tax consulting, business and management consulting, and legal advisory services — as well as restricted services, or certain software used for enterprise management, industrial management and infrastructure. These categories are described as restricted services and restricted software, respectively, and are...

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