By Dr. Johannes Corsten and Dr. Carsten Bormann The European Union’s Russia sanctions regime is evolving rapidly. To date, the EU has adopted 21 sanctions packages. The continual expansion and tightening of these measures—covering new types of conduct and, in particular, additional categories of goods involved in trade with Russia—creates ongoing compliance challenges for companies. While direct shipments to or from Russia have largely ceased in practice, circumvention transactions now present a...
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