April 2022 – In response to Russia's ongoing invasion of Ukraine, the European Union continues (along with other countries) to announce additional sanctions against the Russian Federation and Belarus. Presently, sanctions include, inter alia, bans on the export and import of certain types of goods, doing business with sanctioned individuals and companies and restrictions on new investment activities in Russia.
The consequences of non-compliance with sanctions prohibitions are particularly severe, and include fines of up to CZK 50,000,000 per individual breach. Moreover, the willful breaching of sanctions may qualify as a criminal offence (by both the offending company and also the respective personnel involved) and thus be subject to even harsher penalties.
In light of the above, we advise our clients to:
- always check any goods imported to or exported from the concerned territories against the respective sanctions databases;
- make sure to verify whether the relevant trading partners are subject to sanctions;
- regularly monitor the implementation of sanctions; and
- ensure that all contracts – be they existing or newly concluded – that could in any way be affected by sanctions restrictions contain robust sanctions clauses and end-use statements.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.