February 5, 2023

Volume XIII, Number 36

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February 03, 2023

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February 02, 2023

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REPO Task Force: The First 100 Days

On June 29, the Russian Elites, Proxies, and Oligarchs (REPO) Task Force published a statement on its work in blocking or freezing sanctioned Russian assets.

Created in March 2022 in response to Russia’s invasion of Ukraine, the REPO Task Force is a joint effort between the United States, Australia, Canada, France, Germany, Italy, Japan, the UK, and the European Commission. Since its creation, it has blocked or frozen over $30 billion worth of sanctioned Russians’ assets and coordinated to restrict sanctioned Russians’ ability to use the global financial system. In addition, $300 billion of Russian Central Bank assets have been immobilized and numerous yachts, ships, and real estate seized.

However, freezing and seizing are temporary measures, and legislation will be needed if states wish to strip ownership from sanctioned Russians permanently. The statement notes that “where appropriate and possible, REPO members are undertaking efforts to update or expand and implement their respective legal frameworks that enable the freezing, seizure, forfeiture and/or disposal of assets, for example within criminal law.” The devil will be in the detail, and whether REPO members have learned the lessons of previous rushed legislation is yet to be seen, but in any event legal challenges seem likely. 

In the meantime, REPO acknowledges the role that financial institutions and others play in ensuring the various sanctions regimes are effective and notes REPO members’ use of bank account and beneficial ownership registries to prevent evasion. The pressure on businesses to ensure compliance with sanctions and sanctions-adjacent regulations and the cost of the same is significant, but a failure to invest in doing so may have more expensive adverse consequences.

©2023 Greenberg Traurig, LLP. All rights reserved. National Law Review, Volume XII, Number 189
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About this Author

Of Counsel

Jo Rickards is the Chair of the London office’s White Collar Crime & Investigations Group where she represents a wide range of companies and individuals. Jo is recognised as a leading individual in her practice area advising clients in investigations involving allegations of corruption, cartels, tax and investment fraud and contentious financial services. She has advised directors and companies in the UK and internationally for over 20 years. She represents companies and individuals investigated by the SFO, FCA, CMA and HMRC and those who are subject to mutual legal...

+44 0-203-349-8700
Shareholder

Annabel Thomas is an experienced commercial litigator with a strong background in corporate disputes and civil fraud. She represents clients on matters involving asset-tracing and injunctive relief; partnership disputes; competition law; and regulatory/disciplinary litigation. She also handles company and shareholder disputes (including unfair prejudice claims, breach of directors' duties, JV disputes, LLP disputes and breach of warranty and indemnity claims), as well as insurance disputes (including coverage, subrogated recovery and brokers' negligence). Annabel's...

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Associate

Bethany Histed focuses her practice on commercial litigation, civil fraud, and complex multi-jurisdictional disputes. She has worked on complex contentious cases of significant value involving allegations of fraud, conspiracy, breach of fiduciary and directors’ duties, breach of contract, claims under the Insolvency Act 1986, and unfair prejudice petitions under section 994 of the Companies Act 2006. Bethany also has experience of dealing with asset disclosure and preservation issues.

Bethany acts for a wide range of clients including high-net-...

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Senior Associate

Gavin Costelloe is a senior associate in Greenberg Traurig’s White Collar Defense & Special Investigations Practice in London. Gavin is a former lawyer and prosecutor for the UK’s Serious Fraud Office (SFO). Gavin advises companies and individuals on internal, government and regulatory investigations and compliance issues related to the UK Bribery Act, fraud, market manipulation, anti-money laundering, economic sanctions, and other serious and complex cross-jurisdictional matters. Gavin has considerable experience assisting with diligence for mergers, acquisitions,...

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Kara Bombach, Greenberg Traurig, Washington DC, International Trade and White Collar Defense Attorney
Shareholder

Kara Bombach assists companies to lawfully export goods, technology and services around the globe. She places significant emphasis on helping clients achieve practical, workable solutions to complex regulatory situations arising under anti-corruption and anti-bribery measures (U.S. Foreign Corrupt Practices Act (FCPA) and OECD Convention), export control laws (EAR and ITAR), anti-boycott laws, and special sanctions (embargoes) maintained by the U.S. government (OFAC and other agencies) against various countries (including Iran, Cuba and Sudan), entities and individuals....

202-533-2334
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