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First Response Sanctions

First Response Sanctions. Andrey Goltsblat Managing Partner Goltsblat BLP. 14.08.2014. Introduction of Response Sanctions. List of Goods Banned for Importation. Notes to the ban. The ban does not apply to : goods intended as baby food;

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First Response Sanctions

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  1. First Response Sanctions Andrey Goltsblat Managing Partner Goltsblat BLP 14.08.2014

  2. Introduction of Response Sanctions

  3. List of Goods Banned for Importation

  4. Notes to the ban The ban does not apply to: • goods intended as baby food; • individuals importing these goods for personal consumption; • non-EU European states: Serbia, Montenegro, Macedonia, Albania, Iceland and Turkey.

  5. Sanctions and the Customs Union • To preclude imports into Russia through the Customs Union, the legal mechanism envisaged by the Agreement "On the Procedure for Introducing and Applying Measures Affecting Foreign Trade in Goods within the Common Customs Territory in Respect of Third Countries" may be used. • Article 9 of the Agreement establishes: Upon receiving a notice of unilateral introduction of temporary measures (such as a ban on imports): • the customs authorities of the other parties to this agreement shall preclude importation of goods intended for the party that has applied the temporary measures, unless a licence is issued thereby; • parties that do not apply the temporary measures shall make the requisite efforts to preclude importation of the specified goods into the party state that has applied the temporary measures • So far we are not aware of any notification or ban by Belarus and/or Kazakhstan

  6. Potential Measures Russia Might Take to Preclude Importation of Banned Goods through Belarus and Kazakhstan

  7. Potential Measures to Preclude Distribution of Banned Goods in the Russian Federation • Sales of banned products are not prohibited Meanwhile, sales of banned products may be indicative of: • illegal importation thereof into the Russian Federation; • use of incorrect documents, labels specifying the manufacturer and/or country of origin or information about the manufacturer with respect to such products; • These circumstances might constitute grounds for initiating criminal or administrative offence proceedings.

  8. Potential Measures to Preclude Distribution of Banned Goods in the Russian Federation Assumptions Regarding These Measures • Russian FCS representatives are located on the Belarusian border; they will take part in filtering the commodity flows from the EU member states, thus eliminating any opportunity for importation of goods intended for sale in the Russian Federation, including those imported into the EU from third countries; • It may be expected that, in the foreseeable future, sales of banned products will be prohibited in Russian stores, or trade in these goods within the Customs Union will be restricted.

  9. Contact Information Capital City Complex, Moscow City Business Centre8, Presnenskaya Nab., Bldg.1, Moscow, 123100, Russia Tel.: +7 495 287 44 44 Fax: +7 495 287 44 45 Email: info@gblplaw.com www.gblplaw.com

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