On February 24, 2022, numerous U.S. Government agencies imposed several new economic sanctions and export controls on Russia in response to its invasion of Ukraine to protect “U.S. national security and foreign policy interests.” Then, on March 2, 2022, the White House released guidance with additional actions the U.S. is taking to hold Russia and Belarus accountable for their actions.

The sanctions and export controls imposed by the U.S. and more than 30 countries around the world are aimed to further isolate Russia from the global economy.

Our assessment is that these restrictions focus mainly on key export control policies, all of Russia’s largest financial institutions and global subsidiaries, many Russian elites and family members, defense-related entities and suppliers to the Russian military.

What does this mean for Association leaders with members and activities in Russia?

Information Sharing
Association leaders should conduct an internal assessment of their organization based on their industry to determine whether programs, products, and services offered are not in violation of sanctions.

Outside counsel may be consulted when internal expertise is limited. Associations in science and technology, or those involved in research and development, are urged to proceed with caution, particularly if the information they publish or incorporate into programming may be perceived as advancing Russian military, defense, scientific, or other interests.

In addition, Associations with previously planned conferences or events in Russia may consider delaying or relocating them.

Membership
Regarding Russian membership, most Associations may proceed with caution and continue as usual, since sanctions do not necessarily impact the Association-to-member relationships.

However, Associations may be impacted by a delay of payments associated with membership dues, purchases of other Association products (e.g., publications, certifications), or related services they expect from members or other stakeholders in Russia, given the impact of sanctions on Russian financial institutions.

Furthermore, and as previously stated, depending on the industry and suite of offerings, some Associations may need to limit access to member benefits if such benefits include access to information covered by the sanctions.

While sanctions may only impact some Associations, all leaders are urged to seek additional guidance specific to the organization and industry. Regardless of sanctions, leaders may also consider if adjustments related to their organizations’ business and affiliations in Russia are warranted.

Next steps
As additional economic sanctions and other restrictions are imposed on Russia – or as additional information is released by the U.S. government with direct implications to the Association industry, we will continue to monitor these activities and provide further analysis.

You may also monitor fast-changing developments on these U.S. government websites: State.Gov, Trade.Gov, Treasury.Gov, WhiteHouse.Gov.

For assistance or to arrange a consultation with Factum Global, email [email protected].

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