What are the sanctions and who should enforce them?
Sanctions are a set of measures imposed by competent authorities on states, individuals, legal entities and other entities that violate human rights, provoke ethnic, territorial or religious conflicts, support terrorism or violate other international norms and principles. Sanctions restrictions may apply to individuals, entities, states, goods, services, vessels, etc. Sanctions may include requirements to freeze assets, refuse transactions, refrain from entering into contracts with sanctioned entities and/or persons, refuse loans or other financing, etc.

Sanctions can be imposed by the United Nations (UN), the European Union (EU) or individual countries such as the United States of America (USA) or the United Kingdom (UK), Switzerland, Norway, Ukraine, etc.

International sanctions imposed by the EU (including sanctions imposed by the UN) apply to the territory of the EU and to all EU persons inside or outside the EU. Legality, MB (“Legality”) applies international economic, sectoral, individual and financial sanctions (“Sanctions”), and our clients are also required to be aware of and comply with the Sanctions in their activities.

We also hope that our clients are aware of the aspects of indirect sanctions. Although the buyer, seller or any other party to a transaction is not itself subject to sanctions and is not included on sanctions lists, a shareholder, board member or CEO of a sanctioned company (subject to certain rules) may subject the company to indirect sanctions. In this case, the company is subject to sanctions and restrictions.

What are Legality’s responsibilities and policies regarding sanctions?
Like any other person and/or entity, Legality is responsible for applying and implementing appropriate sanctions policies in its operations. The same requirements apply to Legality’s customers.

We are in compliance with international sanctions:
– United Nations;
– European Union;
– in the countries where Legality will operate, Legality undertakes to comply with the sanctions policy and legislation in force in that country
– or any authority acting on behalf of any of them to impose sanctions.
Legality will exercise caution in complying with the Sanctions and will not take any action (e.g., not transact, provide services or enter into transactions, or provide services only after obtaining authorization from the relevant competent authority) that could directly or indirectly (through intermediaries) circumvent the prohibitions and requirements of the Sanctions.