Spotlight on the “Partner Countries” Exemption from Sanctions against Russia

By Raminta Dereskeviciute, Fabio Cozzi, Sabine Naugès, Dr. Alexa Ningelgen, Renate Prinz, Michal Chajdukowski, Benoit Feroldi, Kai Grandpierre and Dr. Tim Oliver Weill on 2024-06-07

Posted In Sanctions & Export Control

From June 20, 2024, EU companies with a presence in Russia will no longer be able to rely on the “partner countries” exemption and will be required to obtain, or rely on, a licence to provide business services and/or software to their Russian entities.

Competent authorities of the EU Member States responsible for granting licences required pursuant to EU sanctions have taken markedly different approaches in implementing this change.

At the same time, UK sanctions against Russia never contained the “partner countries” exemption and UK companies providing business services to their Russian entities were always required to apply for a licence. In this article, we analyse how the German, French, Italian and the UK regimes are addressing this issue.

Click here to read our full article.

*Trainee Arcangela Gerbino also contributed to this article.

Tags: Sanctions, Partner Countries Exemption, Service Licence

Raminta Dereskeviciute
Raminta Dereskeviciute focuses her practice on product compliance, trade regulation (sanctions and export controls) and ESG. She has significant experience in advising on EU and UK chemical legislation (REACH), product safety and liability rules and frequently represents clients before the European Chemicals Agency Board of Appeal. Raminta also advises businesses on the implications Brexit has in relation to a range of regulatory compliance issues.

Fabio Cozzi
Fabio Cozzi heads the Italian dispute resolution practice and focuses his practice on cross-border litigation, domestic and international arbitration, compliance, financial crime and international trade.

Sabine Naugès
Sabine Naugès counsels clients on all aspects of public law, including administrative and regulatory, competition and constitutional law. Among other high-profile clients, Sabine has advised telecommunications companies France Télécom and Orange on regulatory matters in cases before administrative and commercial courts, and before EU and French competition authorities. She also regularly represents major companies with interests in a wide range of industries, including aerospace, energy, oil and gas, and public health care, before the French government and in litigation, in a range of regulatory and administrative matters.

Dr. Alexa Ningelgen
Dr. Alexa Ningelgen advises major private and public companies as well as authorities on all aspects of public law, including administrative, regulatory, and constitutional law. She has in-depth knowledge of administrative litigation and the relevant procedures.

Renate Prinz
Renate Prinz advises national and international banks and financial service providers, investors as well as industrial companies in all areas of corporate law, M&A and banking supervisory law. She has many years of experience in advising strategic corporate law issues and group structuring, also on the interface with financial regulatory implications in all areas of national and EU financial supervisory law. One of her main areas of expertise is M&A transactions in the regulated sector as well as licensing requirements, in particular for new business models in the financial sector. In addition to traditional banking supervision, she also advises on payment services and crypto securities regulation. She has extensive experience in advising clients in the public sector as well as in the retail sector on corporate and regulatory issues.

Michal Chajdukowski
Michal Chajdukowski focuses his practice on a range of regulatory and trade related matters. Drawing on his experience in financial regulation, he guides national and multi-national clients through the complexity of the UK and EU sanctions regimes and export controls, with a keen eye to cross-border commercial transactions.

Benoit Feroldi
Benoit Feroldi advises both public and private entities on all aspects of public law, including administrative and regulatory law.

Kai Grandpierre
Kai Grandpierre focuses his practice on corporate law. Kai studied law at the University of Münster, the University of Political Sciences and Law, Beijing, PR China and at Texas Tech School of Law in the United States. Prior to joining McDermott, Kai gained valuable experience as a trainee lawyer and research assistant at an international law firm in Cologne.

Dr. Tim Oliver Weill
Dr. Tim Weill advises clients on all aspects of public law, including constitutional, administrative, and regulatory law. He focuses his practice on construction law, particularly in the context of real estate transactions.

Spotlight on the “Partner Countries” Exemption from Sanctions against Russia

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