In a direct response to economic sanctions, Former Russian Prime Minister Dmitriy Medvedev signed two executive decrees in 2019 allowing some companies to omit shareholder and subsidiary information from their corporate disclosures. If fully implemented, the measures could spell serious trouble for the efficacy of U.S. sanctions.
By the Russian Ministry of Finance’s own account, these decrees were drafted with the express purpose of helping at-risk Russian companies evade U.S. sanctions.
And help them they will. These changes to Russia’s corporate disclosure laws are likely to make sanctions enforcement more challenging—if not impossible—for U.S. authorities.
The measures pose significant risks for non-Russian businesses as well — ultimately inhibiting them from conducting adequate due diligence on clients, counterparties, and trade partners. Companies will be unable to assess the risk of doing business with Russian companies that may be linked to sanctioned entities.
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