www.gblplaw.com first response sanctions andrey goltsblat managing partner goltsblat blp 14.08.2014

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www.gblplaw.com First Response Sanctions Andrey Goltsblat Managing Partner Goltsblat BLP 14.08.2014

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Page 1: Www.gblplaw.com First Response Sanctions Andrey Goltsblat Managing Partner Goltsblat BLP 14.08.2014

www.gblplaw.com

First Response SanctionsAndrey Goltsblat

Managing Partner

Goltsblat BLP

14.08.2014

Page 2: Www.gblplaw.com First Response Sanctions Andrey Goltsblat Managing Partner Goltsblat BLP 14.08.2014

Introduction of Response Sanctions

Page 2 © Goltsblat BLP

Page 3: Www.gblplaw.com First Response Sanctions Andrey Goltsblat Managing Partner Goltsblat BLP 14.08.2014

List of Goods Banned for Importation

Page 3 © Goltsblat BLP

Page 4: Www.gblplaw.com First Response Sanctions Andrey Goltsblat Managing Partner Goltsblat BLP 14.08.2014

Notes to the ban

The ban does not apply toThe ban does not apply to:

goods intended as baby food;

individuals importing these goods for personal consumption;

non-EU European states: Serbia, Montenegro, Macedonia, Albania, Iceland and Turkey.

Page 4 © Goltsblat BLP

Page 5: Www.gblplaw.com First Response Sanctions Andrey Goltsblat Managing Partner Goltsblat BLP 14.08.2014

Sanctions and the Customs Union

•To preclude imports into Russia through the Customs Union, the legal mechanism envisaged by the Agreement "On the Procedure for Introducing and Applying Measures Affecting Foreign Trade in Goods within the Common Customs Territory in Respect of Third Countries" may be used.

•Article 9 of the Agreement establishes:

Upon receiving a notice of unilateral introduction of temporary measures (such as a ban on imports):

- the customs authorities of the other parties to this agreement shall preclude importation of goods intended for the party that has applied the temporary measures, unless a licence is issued thereby; - parties that do not apply the temporary measures shall make the requisite efforts to preclude importation of the specified goods into the party state that has applied the temporary measures

•So far we are not aware of any notification or ban by Belarus and/or Kazakhstan

Page 5 © Goltsblat BLP

Page 6: Www.gblplaw.com First Response Sanctions Andrey Goltsblat Managing Partner Goltsblat BLP 14.08.2014

Potential Measures Russia Might Take to Preclude Importation of Banned Goods through Belarus and Kazakhstan

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Page 7: Www.gblplaw.com First Response Sanctions Andrey Goltsblat Managing Partner Goltsblat BLP 14.08.2014

Potential Measures to Preclude Distribution of Banned Goods in the Russian Federation

Sales of banned products are not prohibited

Meanwhile, sales of banned products may be indicative of:

illegal importation thereof into the Russian Federation;

use of incorrect documents, labels specifying the manufacturer and/or country of origin or information about the manufacturer with respect to such products;

These circumstances might constitute grounds for initiating criminal or administrative offence proceedings.

Page 7 © Goltsblat BLP

Page 8: Www.gblplaw.com First Response Sanctions Andrey Goltsblat Managing Partner Goltsblat BLP 14.08.2014

Potential Measures to Preclude Distribution of Banned Goods in the Russian Federation

Assumptions Regarding ThesAssumptions Regarding These e MeasuresMeasures

Russian FCS representatives are located on the Belarusian border; they will take part in filtering the commodity flows from the EU member states, thus eliminating any opportunity for importation of goods intended for sale in the Russian Federation, including those imported into the EU from third countries;

It may be expected that, in the foreseeable future, sales of banned products will be prohibited in Russian stores, or trade in these goods within the Customs Union will be restricted.

Page 8 © Goltsblat BLP

Page 9: Www.gblplaw.com First Response Sanctions Andrey Goltsblat Managing Partner Goltsblat BLP 14.08.2014

Contact Information

Capital City Complex, Moscow City Business Centre8, Presnenskaya Nab., Bldg.1, Moscow, 123100, Russia

Tel.: +7 495 287 44 44

Fax: +7 495 287 44 45

Email: [email protected]

www.gblplaw.com

Page 9 © Goltsblat BLP