BGP Litigation Senior Associate and Attorney Marat Samarskiy has provided the WorldECR magazine, a landmark global publisher on sanctions and compliance, with an insight on the most pressing sanctions matter of Russia’s capital markets realm: designation of Russia’s central depository, the NSD.

Included on the blocking EU Sanctions Regulation list in June, NSD served as a core gateway to the global capital markets for individuals and corporates alike. Once under sanctions, all of them were stripped of their ability to dispose of their assets even though they had nothing to do with the sanctions.

The purpose of the article is not only to provide a superficial view of the matter but also to underline an important message, highlighted among the legal community both at home and abroad: the sanctions should not affect those not supposed to be affected by them. That is why the EU made it possible to grant derogation by a competent member-state authority in order to put things right.

Even though Belgium, Germany and Luxembourg are still considering possible steps, the very situation is still an important beacon for navigating uncharted waters of the sanctions sea.

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