How will the new EU sanctions affect TMT companies with Russian interests?

Recently, both the US and the EU have escalated their respective sanctions regimes against Russia. The purpose of this article is to outline the extent of the latest set of EU sanctions targeted against Russia, Crimea and Sevastapol and to provide some general guidance to technology, media and telecommunications (TMT) companies doing business in Russia. This is clearly a sensitive area given the importance of the Russian market to many international TMT businesses in the future, but the latest sanctions are limited in effect for such businesses. 

On 31 July 2014, the Council of the European Union adopted Regulation (EU) No. 833/2014. The regulation focuses on sanctioning specific sectors of the Russian economy, namely the financial, energy and dual-use/military sectors. These sector-specific sanctions are commonly called ‘Tier III’ sanctions.

Under article 13 of the regulation, the sanctions apply ‘(a) within the territory of the EU ;(b) on board any aircraft or vessel under the jurisdiction of a member state; (c) to any person inside or outside the territory of the EU who is a national of a member state; (d) to any legal person, entity or body, inside or outside the territory of the EU, which is incorporated or constituted under the law of a member state; and (e) any legal person, entity or body in respect of any business done in whole or in part within the EU’…

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