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On 22 October 2018, Russian President Vladimir Putin signed a decree calling for countersanctions against Ukraine and instructing the Russian Government to draw up a list of companies and individuals that will be subject to economic restrictions under the new measures and also a list of the respective restrictions.

The restrictive measures the Russian Government may impose, subject to a decision of the Russian President, could include:

  1. Suspension or termination of cooperation of Russia and Russian legal entities with Ukraine and with entities affiliated with or controlled by Ukraine;
  2. ban or restriction on the import of products and/or raw materials originating from Ukraine or manufactured by entities affiliated with or subject to the jurisdiction of Ukraine (the list of products and/or raw materials will be determined by the Russian Government);
  3. A ban or restriction on the export of products and/or raw materials by entities under the jurisdiction or control of Ukraine (the list of products and/or raw materials will be determined by the Russian Government);
  4. A ban or restriction on the performance of work or provision services for Russian state and municipal needs, and for the needs of certain kinds of legal entities, by entities under the jurisdiction of Ukraine (the list of works/services will be determined by the Russian Government).
  5. A ban or restriction on the participation of certain Ukrainian citizens and legal entities in the privatization of state and municipal property, in the performance of work or provision of services related to the sale of federal property, and/or in the performance of the functions of a seller of federal property.
  6. Other measures as determined by the President of Russia.

The decree further states that it may be repealed in the event that Ukraine cancels the restrictive measures it has implemented against Russian citizens and legal entities.

The decree itself does not impose any countersanctions against Ukraine. It is expected that the respective restrictive measures would be imposed by the Russian Government in the nearest future. Baker McKenzie will monitor further developments.


This legal alert is issued to inform Baker McKenzie clients and other interested parties of legal developments that may affect or otherwise be of interest to them. The comments above do not constitute legal or other advice and should not be regarded as a substitute for specific advice in individual cases.

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