EC Updates Sanctions FAQs on Russia Services Ban
The European Commission on April 2 updated 19 of its Russia sanctions FAQs related to services for the Russian government and entities.
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One FAQ said the services prohibition bars Russian subsidiaries established in the EU from providing barred services to their parent companies in Russia, according to the Global Sanctions blog. As a result, these subsidiaries can't provide any of the "listed services," which include accounting, auditing, tax consulting, business and management consulting, legal consultancy, IT, market research and advertising services.
The commission added that the prohibition doesn't necessarily prohibit nationals of EU member states from working as employees of entities established in Russia, noting that it depends on the service provided. These individuals can provide services that aren't barred by the sanctions. The FAQs also said the ban applies to non-Russian branches of Russian firms that have no unique legal identity.
The commission said its restrictions on legal advisory services cover "the provision of legal advice to customers in non-contentious matters," such as commercial transactions, along with services that involve "participation with or on behalf of clients in commercial transactions, negotiations and other dealings with third parties." The restrictions don't cover legal services for the termination of contracts that aren't "compliant" with sanctions and "for the exercise of the right of defence in judicial proceedings and the right to an effective legal remedy."