On 1 November 2018 the Russian Government adopted Resolution No. 1300 On implementation of Russian President's Decree No. 592 dated 22 October 2018 (the 'Resolution')
The Resolution introduces special economic sanctions with respect to 322 Ukrainian nationals and 68 businesses related to Ukraine and controlled by sanctioned individuals.
The sanction list includes Members of the Ukrainian Parliament, officers of the Ukrainian Presidential Administration and governmental authorities, judges, owners and managers of the large Ukrainian companies, as well as certain companies controlled by high-profile Ukrainian business persons.
Economic sanctions under the Resolution include blocking/freezing bank accounts, electronic securities and assets in the Russian Federation and prohibition of the funds transfers from the Russian Federation. The Resolution comes into effect from the date of its publication.
Based on sanctions implementation practices, the persons included in the sanctions list could be subject to the following other negative consequences:
- certain Russian ministries and authorities will likely also impose restrictions on sanctioned persons;
- restrictions may extend to assets located not only within Russia but also outside Russia in Russian-owned or controlled financial institutions;
- counterparties of the sanctioned persons will be able to claim force-majeure circumstance under relevant contracts.