Many U.S.-based companies that do business with Russia may be happy that recent sanctions in response to the nation’s activities in Ukraine do not include the entire Russian economy.
But that also makes matters more complex for general counsel and others who need to comply with the new regulations.
McGlone points out as well that U.S. companies are required to immediately comply with sanctions, and need to screen business activities in Russia and check lists to ensure they are in compliance. There is no grandfathering option or phase-in provision on these sanctions.
“U.S. persons, U.S. firms are immediately expected to follow these rules as soon as they are published,” McGlone said.