European Commission Issues New Russian Sanctions FAQs
The European Commission updated its Frequently Asked Questions pages that cover its Russia sanctions regime. The new sections relate to imports and purchase of goods, sale of securities, execution of prior contracts and export-related restrictions. Under the contracts FAQs, the…
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commission addresses what is a contract, whether framework contracts are considered as contracts that benefit from the prior contracts exception to the sanctions regime, and what is an ancillary contract, among other things. The securities FAQs cover whether the sanctions apply to transferable securities issued by private companies and whether the sanctions cover the sale of transferable securities to non-Russian entities that are owned by a Russian national, among other scenarios.