EU Updates Guidance for EU Firms Acting on 'Behalf' of Sanctioned Russian Parents
The European Commission issued new guidance this week to clarify how its Russia-related sanctions apply to parties and entities “acting on behalf or at the direction of” a sanctioned Russian party. New FAQ 17 says the commission may consider that…
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an EU subsidiary is acting on behalf of a Russian parent company if the subsidiary obtains approvals from the parent company, carries out “instructions given directly or indirectly” by the parent company, or appoints or dismisses any “authorised representatives” associated with the company. The EU subsidiary may need to put in place “a public trusteeship or a similar firewall measure” to prevent any sanctions violations, the guidance said.