Russia has slowly moved forward in terms of its response to a recent push by the US to levy sanctions in April 2018 against certin Russian state-controlled entities and individuals, and the companies they control.

Last month, legislation was passed in Russia providing the Russian government with the authority to impose certain restrictive measures against certain foreign persons and goods and services in accordance with a decision of the Russian president.

This new law does not in itself impose restrictions. Rather, it provides a general framework under which the Russian president could decide to impose measures.

Areas affected include:

  • the US or any other foreign states that are involved in committing unfriendly acts against Russia, its citizens or legal entities;
  • entities incorporated in any such foreign state that are, directly or indirectly controlled by that state actor or affillated with it; or
  • government officials and citizens of foreign state (associated with unfriendly acts against Russia).

As per similiar legislation in the United States, Russian authorities, entities and citizens would be required to comply with a Russian presidential decision under the new law.

Compliance could include:

  • ending or suspending international cooperation;
  • prohibiting or restricting the import into Russia of certain products or raw materials;
  • prohibiting or restricting the exportation out of Russia by foreign entities or citizens of certain products or raw materials;
  • prohibiting or restricting foreign entities from performing certain work or providing certain services;
  • prohibiting or restricting foreign entities or citizens from being involved in the privatization of state-owned or municipal property, or from performing work or providing services on behalf of the Russian Federation in relation to the sale of federal property; and
  • other measures as may be determined by the Russian president.

The law is sufficient amorphous to allow for variable responses in keeping with Western sanctions presently levied and comptemplated against Russian state actors and associated entities/people.