The United States, along with the European Union and many other
countries, moved quickly over the past few days to impose an
increasingly comprehensive embargo on Russia's financial
sector, with serious collateral impact across Russia's
business sector. Combined with additional export controls levied on
Russia's technology sector, and warnings of more actions to
come, including with respect to cryptocurrencies, the overall
environment poses significant risks to existing or future business
activities involving Russia or companies owned or controlled by
Russian nationals.
This summary is an update to our prior client alert, in which we anticipated
that the United States would move toward expansive sanctions against Russia and
its financial sector for its actions in
Ukraine. We have included a general summary of the broad sanctions
and prohibited transactions current as of today.