Experience

• • Baring Vostok Capital Partners in sanctions compliance aspects of the sale of its stake in Ozon, Russia’s leading e-commerce platform, and other Russian assets held by the private equity firm.
  • A number of U.S. and non-U.S. clients seeking to structure transactions involving Russian sectorally sanctioned counterparties in compliance with U.S. sanctions requirements. In these cases, we have advised clients on how to structure terms so that the clients are not engaging in dealings in new debt or equity issued by the sectorally sanctioned entities; we also have considered how the so-called “50% rule” applies to JVs and other structures.
  • A number of bank clients and others on implications of dealings with entities that are headed by sanctioned individuals. We have, in these instances, counseled on how to avoid direct dealings with those individuals (which would present sanctions risks) while engaging with the non-sanctioned entities that these individuals head.
  • Alavi Foundation in an asset forfeiture jury trial under U.S. sanctions laws and a simultaneous bench trial for turnover of assets under the Terrorism Risk Insurance Act.
  • An Indian company in the sanctions implications of its involvement with a Middle-Eastern oil company with operations in U.S. sanctioned jurisdictions.
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