Conducted an audit of restrictions on transactions with foreign securities

The practice's team advised the client on regulatory and foreign currency restrictions imposed on a broker to conduct transactions with foreign securities for its benefit and for the benefit of its clients, including individuals who are Russian nationals.

Our lawyers analysed current currency and counter-sanctions legislation as well as the regulation of broker and depository activities of a Russian financial institution where a broker’s/depository’s services that are focused on foreign securities were provided to Russian clients by involving foreign sub-brokers and depositories, including the matter of cash movements in relevant accounts.

Following the analysis, we identified transactions and deals which were restricted by current legislation and transactions which despite numerous restrictions were still available for the broker and its clients at that moment. A most complicated audit at the confluence of currency, banking and counter-sanctions legislation enabled the client to structure provision of financial services in compliance with current legislation.