Creates New Challenges and Risks for Businesses
Strained relations between Russia and the U.S. and other countries over the Ukraine crisis has created additional risks for global businesses. Because of sanctions imposed against Russia, U.S. financial institutions and businesses, especially those with Russian and Ukrainian counterparts, should screen existing and future customers, suppliers, service providers and owners of the respective businesses against the names of the persons subject to the orders. U.S. businesses must make themselves aware of whether current or potential clients or customers are ‘listed.’ The ban on entry into the U.S. could impact the ability of U.S. companies to do business with ‘listed’ persons or entities. Sanctions violations can trigger substantial fines and even imprisonment. Civil penalties can range up to $250,000 or twice the amount of the underlying transaction for each violation. Criminal penalties can reach $1 million in fines and up to 20 years of imprisonment. Partners Michael E. Burke and Gene Burd (who is fluent in Russian and conversant in Ukrainian) focus on international business and are well versed in global trade risk. In the video below, Mr. Burke discusses the Foreign Corrupt Practices Act and export control regulations.