Russian Counter-sanctions: Bill Introduced to Criminalize Dissemination of Information That May Result in Introduction or Expansion of Sanctions Against Russian Persons

Following our recent webinar, our Moscow Team prepared an analysis of a draft Russian legislation that would prohibit media communications that reveal non-compliance with sanctions or facilitate imposition of sanctions and would also impose criminal penalties on those that disclose or transfer information to organizations “directly or indirectly” under the control of an “unfriendly state”, any company organized under the laws of an “unfriendly state”, and persons affiliated with such organizations if such transfer or disclosure leads to the imposition or expansion of sanctions.  Continue reading to learn what the bill could mean for businesses based in Russia and elsewhere.

Here are some additional sanctions, anticorruption and compliance related content from us that may interest you:


The presentation slides for the this webinar is now available in the Learning Center section of this blog.  Please contact the presenters with questions.


Our webinar with Lexology to discuss the evolving anti-corruption, sanctions landscapes with respect to the US and Russia and resources for companies to strengthen compliance is set for May 16, 2019 from 9:30 to 10:30 am EDT.

In the years since the US first imposed sanctions against Russia in relation to Ukraine, US sanctions have intensified, expanded and become more nuanced. The number of sanctioned Russian persons has increased, as have the number of Russia-based activities and transactions declared “sanctionable” under US law. Moreover, the Sectoral Sanctions Identification (DSSI) List sanctions marked a move away from simply banning transactions with sanctioned persons to a more nuanced set of prohibitions applicable to US companies.

Russian response has been limited to date, focused mainly on import sanctions on agricultural products, travel bans on certain US members of government, and freezing sanctions on Ukrainian individuals and businesses. Cooler heads have prevailed thus far and retaliatory measures resisted what would be highly damaging to the Russian economy. At the same time, there have been high-profile developments in sanctions enforcement, and white collar crime prosecutions of US nationals in Russia and Russian nationals in the US.

For Russian and foreign companies trying to do business together, the current sanctions and enforcement climate has not been easy to navigate. Join lawyers from our Moscow and Washington DC offices for a Lexology webinar as they discuss:

  • The impact of the current US/Russia legal dynamic on business
  • Compliance best practices that are necessary to avoid enforcement scrutiny
  • Creating a roadmap for an effective response to potential instances of non-compliance

Webinar participation is by invitation only. If interested in attending the webinar, please email us at