What does the poisoning of Alexy Navalny have to do with your business?
If you’re a public company, you may be required to start making additional disclosures and, if you are doing business in Russia, you may have to stop.
The signing of Executive Order 13382 could trigger a reporting requirement if your firm “knowingly conducted any transaction or dealing with any person the property and interests in property of which are blocked pursuant to Executive Order No. 13382 (70 Fed. Reg. 38567; relating to blocking of property of weapons of mass destruction proliferators and their supporters).”
The Executive Order now names six “institutes” that are being sanctioned. So, even if your business is authorized to export there, Section 13(r)(1)(D)(ii) of the Securities Exchange Act of 1934 could require filing a notice (now filed under the title “Iran Notice”) of that transaction.
In addition, the Treasury Department Office of Foreign Asset Control has updated its Specially Designated Nationals and Blocked Persons list with whom business is prohibited.
https://www.cnbc.com/2021/04/16/economists-us-sanctions-mostly-symbolic-and-wont-trouble-russia.html
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