EU-Russia Sanctions - Wind-Down of Intra-Company Exemption for Restricted Professional Services

EU-Russia Sanctions - Wind-Down of Intra-Company Exemption for Restricted Professional Services

• Covington & Burling LLP Manhattan Bolwerklaan 21 Avenue du Boulevard B-1210 Brussels
• Tuesday, March 26, 2024 4:00 PM - 5:00 PM CET

On 26th March at 16:00 Central European Time, Covington & Burling's trade controls practice group will be hosting a meeting and webinar concerning an element of the 12th package of EU-Russia sanctions that has been a source of significant attention in recent months. 

Article 5n of Council Regulation No. 833/2014 (the "Regulation") prohibits, absent licensing or an available exemption, the provision of various professional services to Russian entities, including the following:

• accounting, auditing, including statutory audit, bookkeeping or tax consulting services,
• business and management consulting services
• public relations services
• architectural and engineering services
• legal advisory services
• IT consultancy services
• market research and public opinion polling services
• technical testing and analysis services
• advertising services
• the provision of software for the management of enterprises and software for industrial design and manufacture, together with associated services

These services include services that are routinely provided to corporate affiliates on an intra-company basis.  Article 5n had been subject to a general exemption, authorizing the provision of restricted services for the exclusive use of Russian entities that are owned by, or solely or jointly controlled by, entities established in any EU Member State, a country member of the European Economic Area, or countries listed in Annex VIII to the Regulation (that annex currently includes the United States, Japan, the United Kingdom, South Korea, Australia, Canada, New Zealand, Norway, and Switzerland).

Pursuant to the 12th package of EU sanctions implemented in December 2023, the foregoing exemption will expire on 20 June 2024, after which EU persons will require licensing from EU Member States to continue providing services to Russian affiliates.  This development has raised numerous questions among EU operators, including with regard to the process for seeking licensing, and challenges that many companies face in determining which EU Member State regulators to seek licensing from. 

At the meeting on 26th March, we will share our experiences and understandings from engagements on this subject with the European Commission and various EU Member State regulators, and the meeting will provide an opportunity for attendees to share their own insights and experiences.  We will lead the presentation from our firm's Brussels office and would welcome any participants who are able to make it to our Brussels office to attend in person.  Alternatively, there will be an option to join remotely online. 

Event Details

Tuesday, March 26, 2024
4 - 5 p.m. CET
3 - 4 p.m. GMT
11 a.m. - 12 p.m. EDT

In-Person Location
Covington & Burling LLP
Manhattan
Bolwerklaan 21 Avenue du Boulevard
B-1210 Brussels

Click here to register.

Login-In details provided upon registration.

Presenters

David Lorello, Partner
dlorello@cov.com

Bart Szewczyk, Associate
bszewczyk@cov.com

Emanuel Ghebregergis, Associate
eghebregergis@cov.com