Liability for violation of Russian anti-sanction legislation

Starting January 1, 2024, administrative liability may be established for violations of Russian counter-sanctions measures. Anti-sanctions legislation (counter-sanctions measures) refers to prohibitions and restrictions established by the President, the Government, and the Central Bank of Russia to “influence (counteract) unfriendly actions of the USA and other foreign states” and ensure the financial stability of the country.

In particular, a new article 15.25 “Failure to comply with measures of influence (counter-measures) aimed at ensuring financial stability of the Russian Federation” may appear in the Code on Administrative Offences. The corresponding bill was published on the federal portal of projects of legal acts.

The bill establishes fines for individuals, individual entrepreneurs and legal entities ranging from 20 to 40 percent of the amount of the transaction (operation) carried out in violation of countermeasures or the amount of transaction (operation) not carried out in accordance with the established measures. The penalty for the officials is from 20 to 40 percent of the amount of the transaction (operation) but no more than 30,000 rubles.

If non-compliance with the established measures has no monetary value (for example, performance of gratuitous transactions, opening of special accounts, etc.), the penalty is from 4.000 to 5.000 rubles for individuals; from 40.000 to 50.000 rubles for officials; from 800.000 to 1.000.000 rubles for legal entities.

If a company eliminates violations within a certain period of time, no liability measures are applied.

Administrative cases will be considered by the Federal Tax Service and the Federal Customs Service, and in relation to officials of credit and insurance organizations - by the Bank of Russia. These bodies may request documents and information on compliance with counter-sanctions measures.

The limitation period for bringing to liability amounts to two years from the date on which the offence was committed.