As a result of recent events, there has been an increase in both the type and extent of sanctions imposed on persons and entities in our region. In particular, we anticipate that there will be increasing difficulties in making payments to some of our offices in a foreign currency, especially US Dollars. Within GRATA International, we are monitoring the position and taking steps to coordinate our approach in addressing the disruption caused by the imposition of sanctions. We are also conscious that many sanctions regimes make it an offence to provide legal services to companies and individuals under sanctions or provide assistance in the avoidance of sanctions and some countries, such as the United States of America, claim extra-territorial jurisdiction against non-US persons.
Effectively, this means that from now on it is your responsibility to check all incoming and outbound work for any potential sanctions implications and consider the consequences of taking on a client that might be connected to the sanctions list. Providing legal services, accepting and processing payments, assisting with sanctions circumvention or avoidance all might constitute a breach of sanctions. Please bear in mind that several packages of sanctions have been imposed by the US, Canada, Japan, EU, UK, and others. The implications of sanctions breach may lead to severe consequences not only for the firm but to individuals involved as well. All lawyers and partners are personally responsible for checking relevant sanctions requirements for their projects and clients.
Any breach of sanctions might have a significant impact on colleagues who are based abroad, especially in countries that imposed sanctions. In case GRATA is found violating sanctions, our colleagues in the US (Zulfiya Akchurina), the UK (Andrew Gamble), Germany (Igor Popa) and Switzerland (Dimitri Papadopoulos) will take the hardest hit and may even end up in a situation where will have no choice but to leave the firm.
From this moment, in order for us to support our colleagues in all our offices, we would be grateful if you would provide us with details of any problems that you are facing or any issues that you anticipate arising. If you are considering taking on a client that may be connected to the sanctions list or have any doubts about taking on this risk, please consult with the following colleagues, before proceeding with the project:
