FCPA Compliance Report

Matt Silverman on Potential Sanctions Against Russia

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In this episode of the FCPA Compliance Report, I am joined by Matt Silverman, Director of Trade Compliance at VIAVI. In this Part 1 of a special two-part podcast series, we look at issues related to potential sanctions against Russia, Russian individuals and Russian interests if Russia invades Ukraine. In Part 2, we will discuss what you can do to prepare for such an eventuality. Potential sanctions we review in this episode ininclude:

  1. Impose a comprehensive or near-complete embargo of Russia.
  2. Impose additional sectoral sanctions on certain Russian industries.
  3. Prohibit exports of certain items or technology to Russia.
  4. Designate Russian entities under the Foreign Direct Product Rule.
  5. Add specific Russian entities or individuals to OFAC’s Specially Designated Nationals and Blocked Persons List (“SDN”).
  6. Prohibit Russian entities from accessing the U.S. financial system/using U.S. dollars and/or sanctioning foreign banks that conduct transactions with sanctioned Russian entities.
  7. Prohibit U.S. persons or entities from investing in Russian companies, requiring divestment, and/or sanctioning foreign entities that buy Russian government bonds.
  8. Impose “secondary sanctions” on entities or individuals that conduct certain transactions with Russia.
  9. Freeze Russian assets located in the U.S. 
  10. Ban U.S. financial assistance to Russian entities.
  11. Withhold U.S. aid to any organizations that assist Russia.
  12. Prohibit imports and/or impose high tariffs on specific Russian imports.
  13. U.S. State-Level Sanctions: States may enact laws that prohibit business with, or require divestment of shares in, firms that conduct certain transactions with Russia.


    14. Resources

    Matt Silverman on LinkedIn

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    FCPA Compliance ReportBy Thomas Fox
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