A planned transaction may simultaneously be subject to the rules of several sanctions regimes.
In this case, it is crucial to identify the relevant sanctions regimes regarding each element of the transaction.
For example, suppose an EU-based operator is financing its operations from a loan. In that case, the financing agreement may require other sanction compliance rules in addition to the EU rules (e.g., if the financing currency is USD, the transaction may also require compliance with US sanction rules).
In addition, if the economic player also operates in Russian relations or in Russia, this fact also requires considering the relevant Russian rules, which often do not facilitate full compliance with EU rules.
In the above cases, which regularly arise in our practice, the provisions of at least three sanction regimes have to be applied simultaneously, which often makes the intended transaction significantly more difficult or entails significant risks.
A further preliminary analysis may be required since the banks processing the payments might request information on the parties of the transaction or certain documents (company documents, background information) as a condition for the transfers to be made. The example above describes a standard transaction that occurs regularly in daily practice. In specific cases, there are usually additional aspects that may add complexity to the case and affect "navigation" to the completion of the transaction.
