EU Updates Russia Servicing Sanctions FAQs

The European Commission this week updated its Russia-related sanctions frequently asked questions, including guidance on the restrictions that apply to people and companies providing services to Russia. The updated FAQs cover how sanctions apply in the context of aggregate ownership (page 25); firewalls, which stop a sanctioned person from exercising control over a non-sanctioned EU company, allowing that company to continue normal business operations (page 39); and how sanctions apply to services provided as an employee of an EU mother company to a Russian subsidiary (page 349).