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Global Conflict Zones

Entities with operations or investments in active conflict zones are faced with a daunting set of legal and business challenges. Our lawyers have long been trusted advisers helping companies, banks, institutional investors, and other entities to navigate the quickly changing framework of international sanctions, regulatory issues, and business conditions stemming from global conflicts—and to strike the delicate balance needed to respond swiftly and effectively in these dynamic situations.

Business and investments are ideally conducted in stable environments, and in the face of conflict or turbulent conditions, unprecedented issues can arise from related sanctions, technology trade and supply chain disruptions, rising energy prices, portfolio investment instability, insurance claims, cybersecurity concerns, and a divided employee base, among others. To help our clients meet these moments, we offer this centralized portal to share our insights and analyses on evolving legal developments and government guidance.

Our lawyers are fluent with local laws and practices (not to mention languages) in a wide spectrum of regions—helping them to address and overcome the challenges our clients face and understand what changes may need to be implemented in their global operations.

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With a maze of pure sanctions, applied sanctions, and countersanctions, global conflicts require industries and individual organizations to grapple with disruptions to global supply chains, commodities trading, the flow of transportation industry raw materials, the movement of data, and asset freezes. Our team helps companies address these challenges as well as other regulatory issues including export control laws and regulations, import restrictions, and related compliance matters and litigation.

Additional Resources

03/18/2024 - What 2 Years Of Ukraine-Russia Conflict Can Teach Cos., Law360
In an expert analysis column for Law360 partners David Plotinsky, Vasilisa Strizh, and Vishnu Shankar discuss key legal lessons learned from the conflict in Ukraine. The column, which includes contributions from partners Shannon Donnelly, Daryl Landy, Paul Mesquitta, Sergio Oehninger, and Peter Sharp, delves into how companies can navigate sanctions and counter sanctions resulting from the conflict, and how the situation has affected contract disputes, insurance, cybersecurity, employees, and immigration.
03/11/2024 - Ukraine Conflict – Two Years Later: Key Legal Lessons for Businesses
It’s been two years since the escalation of the ongoing conflict in Ukraine, which has led many companies with business operations or personnel in Eastern Europe to adjust, restructure, or exit locations in Russia. Meanwhile, the global business community has adapted to trade restrictions and sanctions, settled contract disputes and force majeure issues, prepared for and responded to cybersecurity breaches, and navigated challenges to the supply chain.
03/08/2024 - European Council Issues Guidance on Recently Imposed ‘No Russia’ Clause for EU Exporters
EU-based aircraft owners and lessors, among other exporters, will soon have to incorporate a “No Russia” clause in their contracts with non-EU counterparties for the sale, supply, transfer, or export of aircraft and aircraft parts. The obligation to include the clause will vary depending on a contract’s date of conclusion, with the first implementation dates coming as soon as March 20, 2024. The European Council has released guidance and a template for the clause, part of a larger package of sanctions on Russia, to guide impacted EU exporters.
02/28/2023 - US Significantly Expands Export Sanctions on Russia and Belarus; Simultaneously Adds to Entity List and Tariffs
The US continues to increase economic sanctions on Russia and Belarus. February 27 saw multiple actions expanding sanctions, including restrictions on exports of a large swath of equipment and consumer goods, Office of Foreign Assets Control designations, and visa restrictions. The Bureau of Industry and Security, in particular, emphasized that its action is focused on “aligning” with controls previously imposed by allies and partners in Europe.
01/20/2023 - Update: New Decree Allows Certain Russian Companies to Remove Voting Rights of Minority Shareholders and Directors from Unfriendly States
Russian President Vladimir Putin adopted Decree No. 16 on January 17, allowing Russian companies to change their corporate decision-making so that minority shareholders from the so-called “unfriendly states” (or those controlled by persons from such states) and directors nominated by them lose their voting rights at the shareholder meetings in the boards of directors (supervisory boards) and management boards of affected Russian companies.
10/28/2022 - London Court of International Arbitration Is Granted Exemption from Russia and Belarus Sanctions
The United Kingdom’s Office of Financial Sanctions Implementation (OFSI) has granted the London Court of International Arbitration (LCIA) a General Licence allowing it to process payments from designated parties (DPs) who are subject to the United Kingdom’s recent financial sanctions against Russia and Belarus.
10/07/2022 - Update: EU Introduces Its 8th Wide-Ranging Sanctions Package Against Russia
The European Union adopted its 8th sanctions package of restrictive measures against Russia on 6 October 2022 in response to the ongoing conflict in Ukraine.
05/31/2022 - Update: New Russian Decree Restricts Ability of Foreign Rightsholders to Collect License Payments
Russian President Vladimir Putin signed Decree No. 322 “On Temporary Regime For Performance of Obligations Towards Certain Rightsholders” on May 27, prohibiting Russian residents from making license payments to foreign bank accounts of rightsholders residing in “unfriendly states” or otherwise supporting sanctions against Russia.
05/06/2022 - Update: New Russian Decree Introduces Blocking Measures, Authorizes Government to Determine Designated Persons
Russian President Vladimir Putin issued a decree listing several retaliatory special economic measures against legal entities and individuals, as well as organizations controlled by them, to be designated by the Russian government.
04/26/2022 - Update: UK Finalizes Export Ban on Luxury Goods to Russia
The United Kingdom has finalized its ban on the delivery, sale, transit, and export of luxury goods to Russia, focusing on items that will impact Russian oligarchs and other members of the Russian elite.
04/25/2022 - Update: Russia Legalizes Parallel Import of Certain Goods
In light of trade restrictions and foreign companies discontinuing business in Russia, the Russian government resolved to remove legal protection of intellectual property (IP) rights embedded in certain goods and trademarks attached thereto, thus enabling parallel import of such goods to Russia without authorization of the relevant IP holder or authorized distributor.
04/11/2022 - Update: Extensive Sanctions on Russia Focus on Luxury Goods
The European Union, United Kingdom, and United States have introduced a number of extensive sanctions against Russia in relation to the delivery, sale, transit, and export of luxury goods, with the intention of focusing on items that will impact Russian oligarchs and other members of the Russian elite.
04/11/2022 - Update: Russian Draft Law to Criminally Prosecute Directors and Officers for Sanction Compliance
A draft law submitted for consideration to the State Duma—the lower chamber of the Russian parliament—would amend the Russian Criminal Code to make compliance with sanctions a criminal offense for directors and officers, punishable by severe penalties, including long-term imprisonment. If adopted, the law would significantly impact many individuals and businesses in Russia, and companies would need to adjust their strategies toward Russia accordingly.
03/16/2022 - Ukraine-Related Sanctions: Contract Disputes Under Business Agreements Governed by US Law
The conflict in Ukraine has resulted in the disruption of innumerable commercial agreements between and among financial, manufacturing, and other entities. The sanctions imposed by nations and international bodies on various Russian and Belarusian persons and entities as a result of the conflict (Ukraine-Related Sanctions) are in many ways exceptional in their coordination, breadth, and speed. Russia has imposed initial countermeasures in response to the Ukraine-Related Sanctions, which could also affect the performance of commercial agreements by parties across the globe. Many US businesses are considering whether (and if so, how) the operations in Ukraine or the Ukraine-Related Sanctions might impact their and their counterparties’ obligations under agreements that require performance by or with sanctioned entities.
03/15/2022 - US Announces New Restrictions on Export of Luxury Goods to Russia
President Joseph Biden issued Executive Order 14068 on March 11 expanding prohibitions on trade with Russia and announcing new restrictions on Russian imports, exports, and investments—including luxury goods. This executive order, implemented through regulations issued by the Department of Commerce’s Bureau of Industry and Security, directly impacts many retailers, as it effectively restricts US retailers and businesses from suppling any luxury items, as defined by the regulations and the customs tariff codes to Russia. This edition of Morgan Lewis Retail Did You Know? analyzes the executive order—the latest in a series of regulatory actions targeting Russia as a result of the crisis in Ukraine—the Department of Commerce’s implementing regulations under the executive order, and the practical impact both have for retailers.
03/08/2022 - Reviewing Risk Factor Disclosures Amid Russian Sanctions, Law360
In Law360, partners Erin Martin, Carl Valenstein, and Celia Soehner wrote that public companies should consider impacts of Ukraine conflict-related sanctions on Russia and the related supply chain issues when assessing risk factor disclosure.
03/03/2022 - Update: US Sanctions on Russia Have Extraterritorial Implications
In connection with recent Russia-related sanctions issued by the US government, organizations face a variety of issues when navigating the questions of who and what transactions may be subject to the reach of these sanctions. Economic sanctions administrated by the US Department of Treasury’s Office of Foreign Asset Control (OFAC) are often intended to have extraterritorial effect, and therefore can impose significant compliance costs and penalties on US subsidiaries as well as their non-US affiliates or parent entities.
03/02/2022 - Update: Russia Adopts Countermeasures to Support Its Financial Markets
Russian authorities are taking measures on several fronts to support financial markets and keep liquid assets in Russia, including a new set of countermeasures introduced by President Vladimir Putin. Russia’s Central Bank is also playing an important role in mitigating the effect of recent economic sanctions against Russia.
03/01/2022 - Update: European Union Agrees on Further Sanctions on Russia
The European Union’s 25 February wave of sanctions build on, and significantly expand, its existing sanctions on Russia, imposing wide-ranging restrictions on the Russian economy—including in respect of Russia’s access to financial and capital markets—and the oil refining, aviation, and space sectors. More sanctions from the European Union are expected in the coming days, along with announcements on the disconnection of certain Russian banks from the SWIFT system.
02/28/2022 - Update: United States Expands Sanctions, Export Controls in Response to Russian Operations in Ukraine
Based on the evolving military operations of the Russian Federation in Ukraine, the United States has imposed additional sanctions on the Russian Federation, Russian leadership, and various financial institutions and companies. These sanctions, imposed in close coordination with American allies and partners, target Russian banks as well as Russian state-owned and private entities thought to be involved in funding Russia’s actions.
02/28/2022 - Update: Russia Adopts Special Decree on Countermeasures
President Vladimir Putin issued a decree, “On Special Economic Measures in connection with the Unfriendly Actions of the United States of America and Other Foreign Countries” (Decree), on 28 February. This is the first decree addressing Russian economic measures to respond to the recent sanctions adopted by several countries in connection with the current geopolitical situation.
02/24/2022 - Update: US Department of Commerce Imposes Restrictions on Russia
The United States, in concert with Western allies, has imposed sweeping sanctions on Russia in response to President Vladimir Putin’s action in Ukraine. In addition to a full suite of sanctions administered by the US Department of Treasury/Office of Foreign Assets Controls (OFAC), the US Department of Commerce has issued amendments to the Export Administration Regulations (EAR) that impose new restrictions on exports, re-exports, and retransfers of items subject to the EAR to Russia (and releases in Russia), established policies of denial for license applications, and transferred military end users to the Entity List.
02/23/2022 - Ukraine: New US Sanctions (Also Relevant for European Companies), Beck-Blog
In Beck-Blog, special legal consultant Dr. Axel Spies provides an overview of the Russian sanctions authorized by US President Joseph Biden, noting more sanctions are being considered amid the Russian Federation’s recognition of Ukraine regions as independent states.
02/23/2022 - United States Issues New Economic Sanctions Against Russia
In response to the Russian Federation’s recognition of certain regions of Ukraine as independent states which followed an expansion of nearly 200,000 troops on the Ukrainian border, US President Joseph Biden authorized the imposition of additional sanctions against Russia and indicated that further sanctions were under consideration. This LawFlash summarizes these newly issued sanctions.
02/11/2022 - UK Bolsters Sanctions Powers Against Russia
The United Kingdom on 10 February 2022 amended its Russian sanctions law to more easily add persons to its targeted sanctions regime, which enhances the UK’s ability to quickly impose sanctions against most parts of the Russian economy (and their operations worldwide).
07/08/2021 - US and EU Russia Sanctions Update—US/EU (& UK) Overview (and Russian Countersanctions)
The still evolving US sanctions (as well as the EU and now also separate UK sanctions) continue to challenge Russia-related business. The sanctions frameworks are complex, changing, and, at times, inconsistent as well as overlapping. Navigating this complex global framework is made even more difficult by the ongoing unpredictable and reactionary geopolitical environment as the Biden Administration gets underway.
01/28/2021 - Update: EU, UK, and US Sanctions Against Turkey
Recent sanctions imposed by the European Union, United Kingdom, and the United States on Turkey and certain Turkish persons will be of interest to European and American investors in Turkey’s defense and energy sectors. The following update contains a summary of each regime.

As was evident during the COVID-19 global crisis, the way force majeure clauses are written into contracts could take center stage when the regular speed of business is disrupted. If commercial parties are unable to fulfill their duties under contracts because of the sanctions, companies will be looking for support on how to unwind contracts and handle resulting disputes when contracts are broken. And given the intricate intertwining of our global economy, contract terminations at a high level could result in the termination of other contracts down the chain.

Additional Resources

03/11/2024 - Ukraine Conflict – Two Years Later: Key Legal Lessons for Businesses
It’s been two years since the escalation of the ongoing conflict in Ukraine, which has led many companies with business operations or personnel in Eastern Europe to adjust, restructure, or exit locations in Russia. Meanwhile, the global business community has adapted to trade restrictions and sanctions, settled contract disputes and force majeure issues, prepared for and responded to cybersecurity breaches, and navigated challenges to the supply chain.
09/13/2023 - Update: Russia Develops Mechanism to Release Blocked Foreign Investments
The Russian Ministry of Finance recently announced the development of a mechanism for releasing blocked foreign investments and exchanging them for Russian assets blocked abroad. If approved, the initial stage will apply to funds in “type-C” accounts, benefitting retail investors, with a limit of 100 billion roubles (approximately $1 billion). In parallel, the Russian president issued a decree that sets out a procedure for forced exchanges of Russian sovereign bond payments to foreign investors against the blocked Russian funds held with Euroclear and Clearstream.
08/10/2022 - Update: Russia Introduces Ban Restricting Ability of Investors to Exit from Russian Investments in Certain Industries
Russian President Vladimir Putin issued a decree imposing an overall ban on transactions with certain assets, such as securities in certain Russian companies and interests in certain Russian investment projects, if these securities and interests are owned by persons from the so-called "unfriendly states" or persons controlled by such. Assets include shares in certain Russian major entities, energy and subsoil companies and projects, and Russian banks. The new ban restricts the ability of investors to exit from their Russian investments or to restructure their Russian holdings without specific permission of the Russian president.
01/14/2022 - UK CMA Publishes Updated Merger Guidance Following Commencement of NSI Act
The UK Competition and Markets Authority updated its guidance on the merger control regime in the United Kingdom on 4 January 2022—the same day the National Security and Investment Act 2021 came into effect. The updated merger guidance clarifies that the new national security regime is separate to UK merger control and that transactions may be subject to both regimes.
08/10/2021 - Phishing for Force Majeure – What’s the Catch?, Tech & Sourcing @ Morgan Lewis
With the recent onslaught of ransomware attacks, it’s time to revisit force majeure clauses (again). Earlier in the pandemic, we reviewed how COVID-19 could impact force majeure provisions. Since then, there has been a flurry of analyzing, renegotiating, and testing contractual language, as parties work through, or anticipate, pandemic-related difficulties. While contracting parties focus on striking a balance of when, and to what extent, a party’s performance will be excused due to pandemic-related circumstances, a different threat could follow a similar trajectory.
July 2020 - Cross-Border Transactions Caught at the Crossroads: Navigating the Global COVID-19 Crisis Through Force Majeure Provisions
The coronavirus (COVID-19) pandemic has had sweeping effects around the world, and in this era of globalization, business transactions that span multiple jurisdictions and markets have fallen prey to new and unexpected risks presented by the pandemic.

Financial services companies with operations or investments in conflict zones should plan ahead to ensure business continuity in light of evolving sanctions that could impact the way they are able to move money. We guide companies through the web of international sanctions and address myriad issues arising in this space, including how to repay existing debts, access capital, deploy new private equity or venture capital investments, and maintain certain parts of a deal or workstream while unravelling others.

Additional Resources

03/18/2024 - What 2 Years Of Ukraine-Russia Conflict Can Teach Cos., Law360
In an expert analysis column for Law360 partners David Plotinsky, Vasilisa Strizh, and Vishnu Shankar discuss key legal lessons learned from the conflict in Ukraine. The column, which includes contributions from partners Shannon Donnelly, Daryl Landy, Paul Mesquitta, Sergio Oehninger, and Peter Sharp, delves into how companies can navigate sanctions and counter sanctions resulting from the conflict, and how the situation has affected contract disputes, insurance, cybersecurity, employees, and immigration.
03/11/2024 - Ukraine Conflict – Two Years Later: Key Legal Lessons for Businesses
It’s been two years since the escalation of the ongoing conflict in Ukraine, which has led many companies with business operations or personnel in Eastern Europe to adjust, restructure, or exit locations in Russia. Meanwhile, the global business community has adapted to trade restrictions and sanctions, settled contract disputes and force majeure issues, prepared for and responded to cybersecurity breaches, and navigated challenges to the supply chain.
03/14/2023 - Update: Deadline for Mandatory Conversion of Russian Issuers’ Depositary Receipts Has Passed – What’s Next?
The Russian Parliament required in 2022 Russian issuers to terminate their depository receipt programs that entailed the conversion of depository receipts into Russian underlying shares. This LawFlash discusses the current status of depository receipt conversion procedures as well as the regime applicable to Russian underlying shares received as a result of the conversion.
10/13/2022 - Analysis: Russian Law on Stock Conversion Baffles Global Banks, Clients, Reuters
Partner Grigory Marinichev was quoted in a Reuters article about complications global investors and banks have had converting depositary receipts of Russian companies into ordinary shares in compliance with a new Russian law.
09/16/2022 - Update: Russia Introduces Restrictions on Investors’ Ability to Restructure Holdings in or Exit Russian LLCs
Until recently, investors were not generally restricted in selling their (participatory) equity interests in Russian limited liability companies (LLCs). However, Russian President Vladimir Putin issued Decree No. 618, requiring that a prior clearance by the Russian government commission on control over foreign investments is required for direct or indirect transactions with participatory interests in, or resulting in obtaining management rights over, LLCs, if persons connected with the so-called "unfriendly states" or persons controlled by such are involved.
08/15/2022 - Business Insurance Considerations Amid Conflict In Ukraine, Law360
Partners Sergio Oehninger and Peter Sharp and associate Paul Mesquitta authored an article for Law360 detailing insurance policies companies should review in light of the conflict in Ukraine and actions taken by and against Russia that cause supply chain disruptions, operational interruptions, and loss of assets abroad.
08/10/2022 - Update: Russia Introduces Ban Restricting Ability of Investors to Exit from Russian Investments in Certain Industries
Russian President Vladimir Putin issued a decree imposing an overall ban on transactions with certain assets, such as securities in certain Russian companies and interests in certain Russian investment projects, if these securities and interests are owned by persons from the so-called "unfriendly states" or persons controlled by such. Assets include shares in certain Russian major entities, energy and subsoil companies and projects, and Russian banks. The new ban restricts the ability of investors to exit from their Russian investments or to restructure their Russian holdings without specific permission of the Russian president.
08/04/2022 - Update: Business Insurance Considerations Amid Conflict in Ukraine
The conflict in Ukraine and actions taken by and against Russia continue to wreak havoc on global business operations, causing supply chain disruptions, interruptions in operations, and the loss of assets located abroad. With these losses multiplying at a time of economic uncertainty, now is the time for an insurance checkup.
07/11/2022 - Update: Russia Adopts Basic Framework of Eurobonds Replacement, Eases Rules on Repatriation, but Requires Direct Repayment to Russian Lenders
Russian Decree No. 430 was signed on July 5, establishing a basic framework for the replacement of Eurobonds with Russian bonds. The Decree also confirms that debts owed to Russian participants of international syndicates of banks must be repaid directly—not through facility agents from “unfriendly states”—and in rubles at the lender’s option, but at the same time substantially relaxes the repatriation rule with respect to exempt contracts.
07/11/2022 - Update: Russia Adopts Basic Framework of Eurobonds Replacement, Eases Rules on Repatriation, but Requires Direct Repayment to Russian Lenders
Russian Decree No. 430 was signed on July 5, establishing a basic framework for the replacement of Eurobonds with Russian bonds. The Decree also confirms that debts owed to Russian participants of international syndicates of banks must be repaid directly—not through facility agents from “unfriendly states”—and in rubles at the lender’s option, but at the same time substantially relaxes the repatriation rule with respect to exempt contracts.
07/01/2022 - Update: Russia Adopts Draft Law Allowing DR Conversion Without Reference to Foreign Infrastructure
The State Duma, Russia’s parliament lower chamber, adopted draft law No. 116264-8 on June 29, 2022, containing rules allowing the conversion of depository receipts into the underlying Russian shares without a need to go through non-Russian depositary banks, custodians, brokers, and other similar institutions.
06/30/2022 - Update: New Mechanism Established for Repayment of Russian Sovereign Debt
Russian President Vladimir Putin signed Decree No. 394 on June 22, establishing the new mechanism for settlements under the sovereign bonds of the Russian Federation denominated in foreign currency (Eurobonds).
06/02/2022 - Update: Russian Borrowers Must Repay Russian Syndicate Members Directly; Widespread Defaults Anticipated
A new statement from the Russian Ministry of Finance requires Russian borrowers to repay debt owed to Russian lenders participating in international syndicates directly (bypassing mechanisms established by the relevant loan agreements). This requirement may potentially result in large-scale defaults of Russian borrowers.
05/10/2022 - It Takes a Lot of Effort to Get Rid of Russian Depositary Receipts, Frankfurter Allgemeine
Partner Grigory Marinichev spoke to Frankfurter Allgemeine about the recent Russian law on mandatory delisting of Russian companies from foreign exchanges.
05/09/2022 - Update: Russia Extends Restrictions on Dividend Distributions on Limited Liability Companies
Following previously adopted restrictions on payments of dividends in joint stock companies, Decree No. 254 requires that any dividend payment from a limited liability company to its foreign participant connected with an “unfriendly state” must be made in Russian rubles and to a special blocked type “C” account, subject to certain exceptions.
05/03/2022 - Pivot Investment Strategies of Funds to Avoid Russia or Otherwise Take Advantage of New Opportunities, Private Equity Law Report
A recent Private Equity Law Report article referenced a webinar it hosted in April 2021, looking at lessons learned from the pandemic and how sponsors and investors can apply those to successfully prepare for the next market disruption.
04/29/2022 - Update: Russia Limits Transactions with Shares Received Upon Cancellation of DR Programs
The delisting of Russian issuers’ depositary receipts could potentially lead to a disproportional increase in sales of underlying shares in the Russian stock market and contribute to its volatility. In response to this challenge, Russia’s Central Bank introduced a limit on transactions with shares received upon cancellation of depositary receipts.
04/20/2022 - Update: Delisting of Russian Issuers’ Depositary Receipts – The End of an Era?
A new federal law in Russia prohibits Russian issuers from having their shares traded outside Russia via depositary receipts and requires issuers with existing programs to take delisting measures unless they receive a governmental approval to keep the program.
04/20/2022 - Update: Draft Law on External Management over Certain Foreign-Owned Companies Submitted to Russian Parliament
Russia proposed a draft federal law on April 8 amending article 235 of the Russian Civil Code, which would allow the compulsory seizure of assets in cases stipulated by federal laws, and containing rules about such compulsory seizure from persons from, or connected with, the so-called “unfriendly states.” If adopted, this law would create a framework permitting nationalizing assets of these persons without compensation.
04/20/2022 - Update: Central Bank of Russia Imposes Further Currency Control Restrictions
The Central Bank of the Russian Federation has recently been active in adopting secondary legislation clarifying and implementing presidential decrees on cross-border transactions. Such legislation imposes new restrictions which need to be considered in commercial dealings involving Russia.
04/13/2022 - Update: Russia Proposes Draft Legislation Allowing Nationalizing Assets from Persons Connected With ‘Unfriendly States’
Russia proposed a draft federal law on April 8 amending article 235 of the Russian Civil Code, which would allow the compulsory seizure of assets in cases stipulated by federal laws, and containing rules about such compulsory seizure from persons from, or connected with, the so-called “unfriendly states.” If adopted, this law would create a framework permitting nationalizing assets of these persons without compensation.
04/11/2022 - Europe to Pay for Russian Gas in Rubles—Has Anything Really Changed?
Following Russian President Vladimir Putin's pronouncement that buyers from “unfriendly states” pay for Russian gas in rubles, it has been largely unclear, until recently, what this demand would imply in practice.
04/11/2022 - Update: Russia Reintroduces Insolvency Moratorium
An insolvency moratorium first introduced during the COVID-19 pandemic applies to nearly all Russian legal entities, individuals, and sole entrepreneurs, and bans the commencement of insolvency proceedings against Russian obligors.
03/22/2022 - Update: Russia Further Tightens Currency Control Regulations and Directs Banks to Scrutinize Payments Made Abroad
As another measure to support Russia’s financial market, Presidential Decree No. 126 imposes further limitations on cross-border monetary transfers for both Russian and non-Russian residents. However, Decree No. 126 also gives Russian regulators broad discretion to make exceptions from the previously adopted general bans and specific restrictions.
03/20/2022 - Update: Russia Considers and Enacts Measures Against Foreign Investors
In response to sanctions adopted by the United States, the European Union, and other countries in relation to Russia’s operations in Ukraine, the Russian government is taking steps to adopt measures affecting foreign investors’ rights, from nationalization of assets to non-protection of intellectual property rights.
03/16/2022 - Russia May Default if Dollar Bond Interest Payment Made in Rubles, Bloomberg
Partner Grigory Marinichev spoke to Bloomberg about Type C accounts in relation to Russia’s debt settlement.
03/13/2022 - Russia Considers Imposing Special External Management over Certain Foreign-Owned Companies
Russia is considering introducing legislation that, if adopted, will have a dramatic impact on foreign-owned businesses and their strategies concerning Russia. The goal of the proposed law is to (1) warn foreign owners that they may lose their Russian companies if they abandon them and (2) conserve business and preserve jobs by allowing the sale of affected companies’ assets to a Russian third-party.
03/07/2022 - Update: Russia Adopts Decree on Repayment in Russian Rubles of Debt to Foreign Creditors
President Vladimir Putin issued a decree introducing a special procedure for repayment of debt by the Russian state bodies as well as Russian residents (Russian Debtors) to non-Russian creditors related to foreign states that commit “unfriendly actions towards Russia” or that are controlled by such non-Russian creditors (deemed “Creditors from Unfriendly States”). The new procedure will apply to payments exceeding 10 million rubles ($95,000) per month and effectively prevent the free receipt of repayment amounts by Creditors from Unfriendly States.
03/04/2022 - US Universities Sever Russian Ties, Shed Investments Following Ukrainian Invasion, Boston Business Journal
In the Boston Business Journal, partner Carl Valenstein provided his insights on how US universities may consider divesting Russian assets and severing partnerships with entities on the Specially Designated Nationals And Blocked Persons List amid the conflict in Ukraine.
03/02/2022 - Update: Russia Adopts Countermeasures to Support Its Financial Markets
Russian authorities are taking measures on several fronts to support financial markets and keep liquid assets in Russia, including a new set of countermeasures introduced by President Vladimir Putin. Russia’s Central Bank is also playing an important role in mitigating the effect of recent economic sanctions against Russia.
03/01/2022 - Update: European Union Agrees on Further Sanctions on Russia
The European Union’s 25 February wave of sanctions build on, and significantly expand, its existing sanctions on Russia, imposing wide-ranging restrictions on the Russian economy—including in respect of Russia’s access to financial and capital markets—and the oil refining, aviation, and space sectors. More sanctions from the European Union are expected in the coming days, along with announcements on the disconnection of certain Russian banks from the SWIFT system.
02/28/2022 - Update: Russia Adopts Special Decree on Countermeasures
President Vladimir Putin issued a decree, “On Special Economic Measures in connection with the Unfriendly Actions of the United States of America and Other Foreign Countries” (Decree), on 28 February. This is the first decree addressing Russian economic measures to respond to the recent sanctions adopted by several countries in connection with the current geopolitical situation.
02/24/2022 - Ukraine Conflict: Investment Protection and Armed Conflict
While international humanitarian law (ius in bello) also protects personal property, it is only enforceable on a State-to-State level. International investment law, however, provides for direct recourse by the investor against the host State and can therefore be a powerful and effective means of protecting investments during and after armed conflicts.

The flow of natural resources, oil, and gas across many areas of the world has been disrupted, resulting in periods of higher energy costs and increased emphasis on renewable energy. Many active global conflict areas are hubs for life sciences and technology/fintech companies. Companies across industries turn to us to help address larger market challenges in operations, capital raising, revenue growth, entrepreneurial opportunities, and employment.

Additional Resources

03/11/2024 - Ukraine Conflict – Two Years Later: Key Legal Lessons for Businesses
It’s been two years since the escalation of the ongoing conflict in Ukraine, which has led many companies with business operations or personnel in Eastern Europe to adjust, restructure, or exit locations in Russia. Meanwhile, the global business community has adapted to trade restrictions and sanctions, settled contract disputes and force majeure issues, prepared for and responded to cybersecurity breaches, and navigated challenges to the supply chain.
07/14/2022 - FERC Policies Leave Uncertainty on Viability of Natural Gas Infrastructure Development, Reuters
Partner Kirstin Gibbs and associate Pamela Wu drafted an article for Reuters on how new natural gas permitting proposals from the US Federal Energy Regulatory Commission (FERC) could affect the development of new pipelines. This proposal is gaining a lot of attention in the energy industry, as President Joseph Biden has pledged more natural gas to supplement the previous supply from Russia.
05/23/2022 - Update on US Nuclear Industry Export Restrictions to Russia, Up & Atom
It’s getting harder to send anything from the US to Russia, including radioactive materials and nuclear-related equipment. Below are some recent examples of actions that the US government has taken to clamp down on nuclear trade with Russia. In this ever-changing geopolitical landscape, exporters must maintain export compliance vigilance for the items and technology they export.
03/22/2022 - Senators Introduce Legislation to Ban Imports of Russian Uranium; Russia Reportedly Considers Mirror Ban, Up & Atom
A group of four US senators introduced a bill on March 16 to ban imports of uranium products from the Russian Federation. If enacted, such a ban could complicate the refueling of existing commercial reactors in the United States that rely on Russian uranium products. A ban also could extend the schedule in the United States for deploying some advanced reactors, because Russia is a key source of the high-assay, low enriched uranium (HALEU) they plan to use. In a related development, Russia is considering a ban on uranium exports to the United States in retaliation for the most recent energy sanctions on Russia.
03/22/2022 - Senators Introduce Legislation to Ban Imports of Russian Uranium; Russia Reportedly Considers Mirror Ban, Up & Atom
A group of four US senators introduced a bill on March 16 to ban imports of uranium products from the Russian Federation. If enacted, such a ban could complicate the refueling of existing commercial reactors in the United States that rely on Russian uranium products. A ban also could extend the schedule in the United States for deploying some advanced reactors, because Russia is a key source of the high-assay, low enriched uranium (HALEU) they plan to use. In a related development, Russia is considering a ban on uranium exports to the United States in retaliation for the most recent energy sanctions on Russia.
2020–2021 - Morgan Lewis SPARK
Spark, our quarterly update highlights new and amended Russian legislation of importance to companies operating in the Russian energy and mining sectors.

Data breaches and their adverse impact on businesses—including unwelcome publicity and brand damage—pose some of the greatest risks to modern companies. Amid heightened geopolitical tensions, many companies are increasing their cyber defenses as threats of ransomware and data breaches have become increasingly impactful. In addition, a proliferation of misinformation (including AI-generated misinformation) on websites and online platforms and intermediaries is creating strategic business, legal, and reputational risks for businesses. These risks are heightened by recent laws (such as the EU’s Digital Services Act and the UK’s Online Safety Act) that require businesses to more actively moderate online content. Our global cybersecurity, data privacy, AI, and digital regulation teams help companies with crisis management, incident response, regulatory enforcement defense and litigation, online content moderation, AI, compliance, and transactional issues.

Additional Resources

03/18/2024 - What 2 Years Of Ukraine-Russia Conflict Can Teach Cos., Law360
In an expert analysis column for Law360 partners David Plotinsky, Vasilisa Strizh, and Vishnu Shankar discuss key legal lessons learned from the conflict in Ukraine. The column, which includes contributions from partners Shannon Donnelly, Daryl Landy, Paul Mesquitta, Sergio Oehninger, and Peter Sharp, delves into how companies can navigate sanctions and counter sanctions resulting from the conflict, and how the situation has affected contract disputes, insurance, cybersecurity, employees, and immigration.
03/11/2024 - Ukraine Conflict – Two Years Later: Key Legal Lessons for Businesses
It’s been two years since the escalation of the ongoing conflict in Ukraine, which has led many companies with business operations or personnel in Eastern Europe to adjust, restructure, or exit locations in Russia. Meanwhile, the global business community has adapted to trade restrictions and sanctions, settled contract disputes and force majeure issues, prepared for and responded to cybersecurity breaches, and navigated challenges to the supply chain.
05/23/2022 - Russian Law Restricts Compliance with US National Defense Authorization Act
Russia President Vladimir Putin signed the federal law, “On Amendments to the Federal Law ‘On Measures of Influence (Counteraction) on Unfriendly Actions of the United States of America and Other Foreign States,’” on May 1, substantially restricting the ability of Russian banks to disclose information to foreign regulators, in particular, under the US National Defense Authorization Act.
03/07/2022 - Update: Ukraine Conflict Has Implications for Cyberinsurance Policies, Including War Exclusions
The conflict in Ukraine has raised significant cybersecurity concerns for businesses in the United States and across the world, resulting in an increased focus on using cyberinsurance to mitigate any resulting losses. The conflict has also caused insurers to turn their attention to a rarely invoked exclusion in insurance policies: the war exclusion. Certain insurers have recently taken steps toward altering the language of such exclusions. As a result, evaluating the applicability of insurance coverage, including the specific language of any war exclusions contained the policy, is an important first step for businesses as they seek to protect themselves from cyberthreats.
02/03/2022 - Key Laws Affecting Ecommerce, Technology, Media, and Privacy Sectors in Russia: 2021 Year in Review, Tech & Sourcing @ Morgan Lewis
As technology and the use of the internet continue to evolve, lawmakers remain focused on setting a legal framework for businesses operating “online” in Russia. In 2021, the Russian regulatory landscape underwent significant changes, which will no doubt have an impact on how tech and media companies conduct their business in Russia.
11/19/2021 - Expanded Safeguards Rule Applicable to More Financial Institutions; Gives More Specificity on Security Requirements
The Federal Trade Commission recently finalized a long-discussed update to its cybersecurity Safeguards Rule that includes more specific criteria for what financial institutions must implement as part of their information security programs. Among other key changes, many companies are likely to be impacted by an expansion of the rule’s scope to include “finders,” which may allow such businesses (including fintech firms) to avoid the current regulatory burden and confusion of state law requirements.

For businesses with personnel located in conflict zones, moving their people out of harm’s way is a top priority. Our global immigration team works with a trusted network of labor, employment, and immigration counsel to help our clients overcome international travel, visa, and work permit issues. Our deep bench of immigration experts coordinate with local counsel globally—allowing us to provide practical and actionable advice to help ensure employee mobility during a crisis or in the face of cross-border conflicts.

Additional Resources

03/18/2024 - What 2 Years Of Ukraine-Russia Conflict Can Teach Cos., Law360
In an expert analysis column for Law360 partners David Plotinsky, Vasilisa Strizh, and Vishnu Shankar discuss key legal lessons learned from the conflict in Ukraine. The column, which includes contributions from partners Shannon Donnelly, Daryl Landy, Paul Mesquitta, Sergio Oehninger, and Peter Sharp, delves into how companies can navigate sanctions and counter sanctions resulting from the conflict, and how the situation has affected contract disputes, insurance, cybersecurity, employees, and immigration.
03/11/2024 - Ukraine Conflict – Two Years Later: Key Legal Lessons for Businesses
It’s been two years since the escalation of the ongoing conflict in Ukraine, which has led many companies with business operations or personnel in Eastern Europe to adjust, restructure, or exit locations in Russia. Meanwhile, the global business community has adapted to trade restrictions and sanctions, settled contract disputes and force majeure issues, prepared for and responded to cybersecurity breaches, and navigated challenges to the supply chain.
03/21/2022 - UK Announces Immigration Rule Changes Applicable to Ukrainian Nationals
The UK government has announced a number of changes to the UK immigration rules applicable to Ukrainian nationals in response to the ongoing humanitarian crisis. Ukrainian nationals remain visa nationals, which means that they require a visa in order to travel to the United Kingdom, regardless of their intended length of stay. This LawFlash summarizes the available UK immigration routes to these individuals.

Employers often find themselves balancing on a tightrope between supporting employee expression—including employers’ own public statements—and creating a safe and respectful workplace for their employees. Our labor and employment team helps companies find the delicate balance between the laws that govern protected political speech and those that prohibit discrimination through many of the developments shaping the past decade, including the #MeToo movement, the murder of George Floyd, the Middle East conflict, and challenges to diversity, equity, and inclusion (DEI) practices.

03/18/2024 - What 2 Years Of Ukraine-Russia Conflict Can Teach Cos., Law360
In an expert analysis column for Law360 partners David Plotinsky, Vasilisa Strizh, and Vishnu Shankar discuss key legal lessons learned from the conflict in Ukraine. The column, which includes contributions from partners Shannon Donnelly, Daryl Landy, Paul Mesquitta, Sergio Oehninger, and Peter Sharp, delves into how companies can navigate sanctions and counter sanctions resulting from the conflict, and how the situation has affected contract disputes, insurance, cybersecurity, employees, and immigration.
03/11/2024 - Ukraine Conflict – Two Years Later: Key Legal Lessons for Businesses
It’s been two years since the escalation of the ongoing conflict in Ukraine, which has led many companies with business operations or personnel in Eastern Europe to adjust, restructure, or exit locations in Russia. Meanwhile, the global business community has adapted to trade restrictions and sanctions, settled contract disputes and force majeure issues, prepared for and responded to cybersecurity breaches, and navigated challenges to the supply chain.

As many corporations, philanthropies, and individuals ramp up charitable giving and philanthropic activities in times of global conflict and crisis, it is important to engage seasoned tax counsel to ensure that funds are being directed to legitimate relief efforts and recipient organizations, that such interventions are structured appropriately, and that all tax and compliance implications are properly considered. Our tax-exempt organizations team helps individuals, philanthropies, and corporations structure and design grants, program and mission-related investments, and relief efforts and programs targeted at the people and communities impacted by global conflicts.