Beware of the risks of incorrect application of international sanctions
- Business partner verification – are business partners or their owners on sanction lists?
- Attention! Sanctions are only applied to companies if the sanctioned owner has at least a 50% stake in them
- Bans in specific sectors – such as energy – need to be monitored
- Is the subject of the contract subject to sanctions? Products made of steel or iron, luxury products
- Pay attention to the transitional periods for imports of steel and iron products
- Banking and monetary restrictions need to be taken into account
- Pay attention to local national restrictions (ban on coal imports in Poland, planned exclusion of entities from public procurement in Slovakia)
- The obligation to report the assets of sanctioned persons
Please note that if you do not apply the applicable sanctions, your company may face a fine or it is possible that no claims from such a transaction will be recognised. The potential reputational risks must also be considered. If sanctions are applied beyond the applicable framework, there is a risk that your company will bear the consequences of a breach of contract. If you are unsure, we recommend complying with reporting obligations under national implementing law for international sanctions.
A document summarising the sanctions imposed in response to Russia's invasion of Ukraine: https://www.eversheds-sutherland.com/documents/global/Slovakia/en/Russian_and_Belarusian_sanctions_update.pdf
- Jan Kohl
- Junior Associate
- +420 255 706 517