The latest modification of the European Union's sanctions against Russia (the so-called "eighth package") banned the provision of a number of professional services to companies and organisations in Russia (EU Regulation 833/2015, Article 5n).
The regulations banning the provision of services generally prohibit certain activities, including legal advisory services.
However, the provisions clearly specify which legal services do not fall within the scope of the generally prohibited "legal consultancy services".
For instance, these include representation, advising, preparation or review of documents in ongoing cases or proceedings before administrative bodies, courts or officially recognised courts and tribunals or in arbitrational proceedings or through mediation.
The regulations determine additional conditions for exemption (participation in proceedings in Member States, provision of advice to Russian companies controlled by companies incorporated in Member States, etc.), and in some instances, the competent authorities of Member States may also authorise the provision of services which are prohibited under the main rule.
The multi-layered exemption regime requires that the service to be provided in each specific case must be qualified under the above rules. Then, depending on the result, it must be decided whether to provide the service in question or not.
