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BCLP Partner Megan Gajewski Barnhill was quoted March 21 in Times of Israel concerning sanctions and export controls imposed as a result of the Russia-Ukraine conflict. When assessing a deal with Russia, US sanctions may apply if there is a US person involved or the transaction occurred entirely or in part in the US. If that is the case, then the “US is going to seek jurisdiction over that transaction,” Megan said. A US person could be a US citizen or US permanent resident (holder of a green card), wherever they are located. So, if there is a US citizen or green card holder working for a non-US company in Israel, they would be subject to all of the prohibitions under the US sanctions, “and they have to abide by those in their individual capacity,” she noted.

Megan’s comments were sourced from the March 7 webinar with Tel Aviv-based firm Shibolet & Co. that focused on the wide array of sanctions and export controls that have been imposed by governments and organizations outside of Israel in response to the conflict in Ukraine.

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