NAVIGATING RUSSIA SANCTIONS COMPLEXITIES
R&C: What do you consider to be among the significant recent developments affecting Russia sanctions? How would you characterise their implications?
Kadel: Since 2014, the US, and its European allies, have applied a wide range of targeted sanctions in response to various Russian behaviours and actions, including the invasion of Ukraine and the annexation of the Crimea region, human rights abuses, cyber attacks on Western governments, companies and institutions, and other harmful foreign activities. The US has expelled Russian diplomats, sanctioned individual Russians and their companies, sought to limit Russian access to a range of economic and financial transactions in the global market, and increased certain technology and other export controls. In the first 10 months of the Biden administration, the targeted sanctions approach toward Russia sanctions has been maintained. But there have been reports that the effects of targeted sanctions are not seen by policymakers as doing enough to prove sufficient to deter Russia from further cyber attacks, influence operations and other objectionable foreign initiatives. Reports have described the Biden administration’s most recent targeted initiatives as meant to ‘cut deeper’ than previous efforts to target Russia and impose ‘real costs’, but it remains to be seen whether the targeted sanctions of the Biden administration will have more success in achieving the ultimate goal of modifying Russian behaviour. If the goals of targeted sanctions are not achieved, will Russia-related sanctions remain targeted, or become more comprehensive? And if they remain targeted, will the targeting in fact ‘cut deeper’ than previous targeted sanctions efforts?
Jan-Mar 2022 Issue
Cardinal Health
Gibson, Dunn & Crutcher LLP
Sullivan & Cromwell LLP