Russian entities - who's in control?

There has been much debate regarding whether to treat entities associated with the Russian state as sanctioned on the basis that they are subject to the "control" of President Putin or other senior officials who are designated persons under UK sanctions, pursuant to Regulation 7(4) of the Russia sanctions regulations. Alexandra Webster of Simmons & Simmons finds instruction in recent case law.

Alexandra Webster (+44 (0)20 7825 3602, alexandra.webster@simmons-simmons.com) is a managing associate in the Crime team at Simmons & Simmons. She advises corporate clients across a range of sectors on sanctions risk management, litigation and compliance matters.

There has been much debate regarding whether to treat entities associated with the Russian state as sanctioned on the basis that they are subject to the "control" of President Putin or other senior officials who are designated persons under UK sanctions, pursuant to Regulation 7(4) of the Russia sanctions regulations. Alexandra Webster of Simmons & Simmons finds instruction in recent case law.