Recent changes to EU sanctions against Russia mean that EU operators will
need to do more in terms of sanctions risk assessment, due diligence and
mitigation measures. In particular, they are now expected to use their best
efforts to prevent non-EU group entities from undermining the sanctions against
Russia, expanding the relevance of these measures beyond the Union. In
addition, ever-tighter restrictions make it more difficult for EU companies
still active in Russia to remain compliant, while exiting Russia proves equally
challenging and may take years. At the same time, Russian courts aggressively
claim jurisdiction over any conflict involving foreign sanctions. Export
controls also continue to evolve, with more and more restrictions on
strategically relevant trade between the US and EU on the one hand and China on
the other.