International Trade ♦ Note 64 Va. J. Int’l L. 447 (2024)

Between Scylla and Charybdis: Sanctions Compliance for International Companies Divesting from Russia

SIMON VOLKOV

This Note offers an overview of the U.S. and Russian economic sanctions following the outbreak of the War in Ukraine. It examines the regulatory conflicts companies face when complying with U.S. or Russian sanctions and the challenges international companies encounter when divesting from Russia. The Note emphasizes the complexities of navigating international sanctions, suggests potential divestiture strategies without violating both sets of sanctions, and proposes potential additional clarification from the Office of Foreign Assets Control to resolve regulatory conflicts.