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Embargo for Crimea?
Is business activity on the peninsula still possible? On 18th December, the EU announced new sanctions regarding doing business with Crimean legal entities and doing business in Crimea. The next day, the US followed with similar sanctions. Here is an overview of the changes.
The EU: what is new?
The new EU sanctions forbid all investments in Crimean legal entities, including acquisition of shares or securities of a participating nature. Acquisition of real estate in Crimea or extension of current participation in real estate is also forbidden. New sanctions forbid providing financing to legal entities in Crimea, creating joint ventures with such legal entities, or providing investment services directly related to such activities (for example, providing investment services to a company from a third country). Contracts concluded before 20th December can be executed.
The new EU sanctions also target the tourist industry, and providing services directly related to tourism activities in Crimea is now forbidden. No ship providing tourism services is allowed to enter any of seven listed ports in the Crimean peninsula (Sevastopol, Kerch, Yalta, Theodosia, Evpatoria, Chernomorsk, Kamysh-Burun) except in case of emergency (only two ports were banned previously; the Kerch and the Sevastopol sea ports, as well as the Kerch ferry).
Selling goods and services to Crimea is not forbidden as long as the goods and services are not related to listed sectors (transport, telecommunication and energy infrastructure as well as exploration of mineral resources).
Can I register a new company in Crimea?
No. Opening a new company or acquiring a company or shares of a company is forbidden. It is also forbidden to finance such deals, to perform portfolio management for such investments, or even to provide investment advice on such deals.
What will happen to my existing company in Crimea?
Existing property rights are not affected by the sanctions. Usual business activity of an existing legal entity registered in Crimea (for example activities related to buying or selling goods or services) is permitted as long as business is not related to the forbidden sectors (transport, telecommunication, exploration of mineral resources etc.) or forbidden activity (financing the acquisition of legal entities or real estate and other activities). On the other hand, as Crimea is seen by the Ukrainian authorities as a part of Ukraine, a company having offices in Kiev and in Crimea could face certain problems.
Can I increase capital of my subsidiary in Crimea?
No. Any provision of financing, including equity capital, to an entity in Crimea or Sevastopol is forbidden for companies registered in the EU. It is also forbidden to finance a company in a third country with a purpose to provide financing for an entity in Crimea or Sevastopol.
Can I continue to operate a branch in Crimea?
As providing financing for any entity registered in Crimea is forbidden, it is questionable whether or not the running of an economically dependent branch in Crimea would conform to the sanctions.
Can I visit Crimea?
Yes, it is still possible. An EU citizen may still go to Crimea for tourism or business purposes. Caution is still needed, as in case of emergency EU countries may not always be able to provide consular support to their citizens visiting Crimea. Also, an EU national providing economic resources to listed entities (like hotels, ferries or other companies mentioned in the sanctions list) in the form of buying their goods or services may violate the new regulations.
The US: what is new?
The US has introduced Crimea-related sanctions as well as adding 17 individuals and 7 legal entities to the SDN list (which forbids any economic activities with the sanctioned persons). The new US sanctions forbid any new investments in Crimea. Direct or indirect importation of any goods, services or technologies originating from Crimea to the US is also forbidden (the EU allows such imports if exports from Crimea are permitted by the Ukrainian authorities). Selling or supplying goods, services or technologies to Crimea from the US (including re-exportation) is also forbidden (the EU does not forbid such activities). This has further consequences, for example it is impossible to pay with a Visa or MasterCard credit card in the territory of the Crimean peninsula as Visa and MasterCard have stopped providing services there.
How do I protect myself?
As new sanctions are getting more and more complicated, including a total of over 200 private persons and companies affected by different sanctions regimes, it is very important to check every economic contact and every transaction to be on the safe side. We at RUSSIA CONSULTING have developed our own search engine that allows us to check the ownership structure of almost every Russian partner, supplier, client and company, and to compare this with the sanctions lists. This procedure allows our clients to find out whether their partner, supplier, or client is affected by the sanctions and whether economic contact with this company is permitted.
For further questions, please contact Russia Consulting