The law firm claims a growing number of UScompanies are scrambling to determine if their trade partners are tied to individualstargeted by the most recent round of sanctions aimed at President VladimirPutin’s inner circle.
“The fluid situationand rapidly changing sanctions create significant risk management challengesfor companies doing business in Russia and parts of Ukraine,” the firm, whichhas a practice dedicated to shipping, wrote in an email alert emailed issued Mondayevening.
“Unlike typicalindividuals whose assets are blocked by the US Treasury Department's Office ofForeign Assets Control (OFAC) some of the Russian oligarchs targeted forsanctions may own and control a number of companies which would then beconsidered sanctioned entities.”
The firm urged companiesto stay current on which individuals and entities are subject to sanctions issuedby the Obama Administration that prohibit domestic companies from doingbusiness with what are known as “specially designated nationals” or “SDNs”.
It also warned clientsto check to ensure that their business partners in Russia and Ukraine arenot affiliated with any of these SDNs, develop contingency plans in casespecific sectors are targeted and consider the “real possibility” that Moscowwill counter with sanctions of its own.
To date, Holland& Knight says OFAC and the Obama Administration have taken aim at more thantwo dozen SDNs. The list is comprised of Ukrainian officials, several Russiangovernment officials, members of Putin’s inner circle and one Russian bank, Bank Rossiya.
The list, which identifies30 individuals and entities in total, includes the likes of Vladimir Yakunin, aclose confidant of the Russian President who has been active in variety ofdifferent transportation sectors and used to serve as chairman of Sovcomflot affiliateNovoship.
Some observers admit they were caught off guard when they first received Holland& Knight’s warning since so many market researchers are telling clientsthat the crisis in Crimea is unlikely to have a significant near-term impact onthe shipping industry in general.
