Month: September 2025

Companies engaged in international trade understand that doing business with jurisdictions subject to sanctions — such as Russia and Belarus — or with third countries that may be viewed as facilitators of such trade is still legally possible. However, navigating this environment has become increasingly burdensome due to the constant influx of new and evolving sanctions, shifting interpretations, and emerging court practices. In this complex landscape, clear and well-documented compliance is no longer optional — it is essential for ensuring smooth and uninterrupted transactions, particularly in the face of heightened scrutiny from banks and regulatory bodies.

Furthermore, EU Regulation 833/2014 implies that due diligence and sanctions compliance are no longer just ‘best practices’ — they are mandatory. The keeping up with evolving rules — while managing your daily operations — is overwhelming. If you don’t have time or capacity to train an internal compliance officer, we can step in and support you fully.

Compliance Dossier — Fast and Thorough

Our firm provides end-to-end compliance support, helping you build a solid legal file to justify your business transactions — internally, to your bank, and to regulators if needed.

Our dossier services include:

• Evaluation of counterparties and end-users against personal sanctions limitations
• Verification of TARIC codes, export controls, and end-use restrictions
• Review of trade transactions under the evolving framework of EU sanction law
• Preparation of a defensive compliance file to prevent fund blocking and goods delays
• Practical advice on how to communicate with your bank’s compliance department

Sanctions Legal Advisory Services: EU + Russia

In addition to compliance file preparation, we offer in-depth legal advisory services on both EU and Russian sanction law:

EU Sanctions & Export Control Advisory:

• Guidance on interpreting the latest EU sanctions packages
• Analysis of grey-zone scenarios (e.g., third-country trade, indirect exposure)
• Tailored recommendations for compliance policy updates

Russian ‘Anti-Sanctions’ and Counter-Measures:

• Legal analysis of Russian counter-sanctions legislation and government decrees
• Opinions on the risks of criminal or administrative liability for directors of foreign companies and non-resident individuals doing business in or with Russia
• Strategic advice on navigating reciprocal measures and restrictions by Russian authorities
• Support in handling asset freezes, blocked accounts, and local compliance duties

Why You Should Act Proactively

Even if your business is fully legal, lack of documentation or regulatory clarity can get your transaction blocked — by your own bank or a cautious counterparty.

With our help you can both prove the lawfulness of your trade, preempt banking issues before funds are transferred, avoid personal and corporate liability exposure, safeguard your cross-border contracts.

We support

• Exporters/importers of non-restricted goods
• Service providers with cross-border obligations
• Traders using third countries to reach Russian or Belarusian markets
• Foreign companies with Russian assets or ongoing or winding-down operations
• Businesses concerned about banking rejections or liability exposure

Let Us Handle Sanctions Compliance — So You Can Focus on Business

Your team should not have to decode every EU regulation or monitor Russian legal updates. That is what we are here for. At Juralink, we combine legal expertise with practical execution: we screen, document, analyze, and defend your right to trade legally and transparently. We provide ongoing support, act as your external compliance officer, and help you avoid mistakes that could lead to blocked transactions, reputational risk, or legal consequences.

Contact us today for an initial consultation.

Many companies — both from the European Union and the Russian Federation — are currently facing problems with the recovery of advance payments made under contracts affected by the EU sanctions. This issue typically arises where advance payments were made under contracts for goods or services which subsequently became subject to export restrictions.

Under the Article 11(1) of EU Regulation No. 833/2014 (hereinafter ‘Regulation’), any claims arising from such contracts cannot be fulfilled if asserted by sanctioned individuals, or generally by Russian persons, entities, or organizations, or on their behalf.

However, despite this, the Article 11(3) of the Regulation allows affected parties to pursue legal proceedings to review the lawfulness of non-compliance with contractual obligations, in this case — failure to return the advance payment, whereas another important provision introduced in 2024, namely the Article 11(4), creates a useful legal tool for the parties to actually be able to execute the required transfer the funds. According to this provision, EU authorities may authorize a payment, following a case-by-case assessment, if it is strictly necessary for withdrawing of the EU company’s investments from Russia or winding down business operations there. This authorization can be granted until 31 December 2025.

What does this mean in practice?

If a EU company is in the process of exiting the Russian market or closing out business activities there, it is possible to apply for a ‘license’ to refund any advance payments it has received from Russian business partner(s). The application must be submitted by the EU-based seller of the goods/services to the EU authorities granting such licenses. Depending on the situation this approach can offer a practical legal solution that benefits both contract sides:

• The Russian buyer is able to recover pre-paid funds and comply with the Russian currency legislation;
• The EU-based seller can formally terminate the business relationship, avoid the risk of litigation, and demonstrate compliance with contract obligations — which might be valuable for maintaining good standing should business ties resume in the future.

In Germany, for example these authorizations are handled by the Deutsche Bundesbank and a positive practice of obtainment of such licenses already exists.

Hereto if your Russian business partner requests a refund but you or your executing bank are unsure whether you are legally allowed to process it, our team can advise on whether the specific conditions for authorization are met — and, where applicable, guide you through the license application process.

Furthermore, should no agreement be reached between the parties, the Russian party may also initiate court proceedings in the EU under Article 11(3), during which the court may rule on whether the EU-based party is required to apply for authorization under Article 11(4).

Our legal team can support you at every step — from preparing a strong justification for the refund to handling communications with the authorized authorities.

Time is critical: Given the current deadline of 31 December 2025 (unless a term extension is adopted by a subsequent sanction package), we recommend that companies intending to seek refunds, or needing to respond to such requests, act without delay. The approval process can take quite a time, so that interested parties should initiate the license application as soon as possible.

If you have questions about this process or wish to begin an application, we will be glad to assist you.