"Disentanglement – Hard Choices for Western Companies Still in Russia," Money Laundering Bulletin

In their recent article for Money Laundering Bulletin, Partner Rob Dalling and Senior Associate Karam Jardaneh discuss the dramatic impact of Russian sanctions on Western companies. The authors highlight how multinational corporations with a physical presence in Russia have had to deal with a complex and challenging suite of risks.

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Initial reports in the media following the invasion suggested a rush by Western companies for the exit door. A range of factors are likely to have been in play. For some, the legal risk around sanctions compliance may have been regarded as simply too high. For others, concerns may have been of a more reputational nature. There were additional risks in the form of potential expropriation by the Russian state. Taken together, these considerations created a powerful incentive in favour of a complete departure from the market, and many companies followed exactly that course. Many, however, did not. 

Pursuing a more or less orderly exit from Russia might appear to be the obvious choice for a company wishing to avoid sanctions risks altogether, but despite Western governments offering some assistance to companies on these issues, there are also sanctions complications with exiting the country.

Much recent commentary on these topics has emphasised that the rate of legislation is expected to slow, with a shift in focus to tackling circumvention and pursuing enforcement. However, the compliance burden imposed on businesses as a consequence of Western foreign policy shows no sign of abating.

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© 2026 Jenner & Block LLP. Attorney Advertising. Jenner & Block LLP is an Illinois Limited Liability Partnership including professional corporations. This publication, presentation, or event is not intended to provide legal advice but to provide information on legal matters and/or firm news of interest to our clients and colleagues. Readers or attendees should seek specific legal advice before taking any action with respect to matters mentioned in this publication or at this event. The attorney responsible for this communication is Brent E. Kidwell, Jenner & Block LLP, 353 N. Clark Street, Chicago, IL 60654-3456. Prior results do not guarantee a similar outcome. Jenner & Block London LLP, an affiliate of Jenner & Block LLP, is a limited liability partnership established under the laws of the State of Delaware, USA and is authorised and regulated by the Solicitors Regulation Authority with SRA number 615729. Information regarding the data we collect and the rights you have over your data can be found in our Privacy Notice. For further inquiries, please contact dataprotection@jenner.com.

"Disentanglement – Hard Choices for Western Companies Still in Russia," Money Laundering Bulletin

In their recent article for Money Laundering Bulletin, Partner Rob Dalling and Senior Associate Karam Jardaneh discuss the dramatic impact of Russian sanctions on Western companies. The authors highlight how multinational corporations with a physical presence in Russia have had to deal with a complex and challenging suite of risks.

Read More

Initial reports in the media following the invasion suggested a rush by Western companies for the exit door. A range of factors are likely to have been in play. For some, the legal risk around sanctions compliance may have been regarded as simply too high. For others, concerns may have been of a more reputational nature. There were additional risks in the form of potential expropriation by the Russian state. Taken together, these considerations created a powerful incentive in favour of a complete departure from the market, and many companies followed exactly that course. Many, however, did not. 

Pursuing a more or less orderly exit from Russia might appear to be the obvious choice for a company wishing to avoid sanctions risks altogether, but despite Western governments offering some assistance to companies on these issues, there are also sanctions complications with exiting the country.

Much recent commentary on these topics has emphasised that the rate of legislation is expected to slow, with a shift in focus to tackling circumvention and pursuing enforcement. However, the compliance burden imposed on businesses as a consequence of Western foreign policy shows no sign of abating.

Related Capabilities

Related Locations

© 2026 Jenner & Block LLP. Attorney Advertising. Jenner & Block LLP is an Illinois Limited Liability Partnership including professional corporations. This publication, presentation, or event is not intended to provide legal advice but to provide information on legal matters and/or firm news of interest to our clients and colleagues. Readers or attendees should seek specific legal advice before taking any action with respect to matters mentioned in this publication or at this event. The attorney responsible for this communication is Brent E. Kidwell, Jenner & Block LLP, 353 N. Clark Street, Chicago, IL 60654-3456. Prior results do not guarantee a similar outcome. Jenner & Block London LLP, an affiliate of Jenner & Block LLP, is a limited liability partnership established under the laws of the State of Delaware, USA and is authorised and regulated by the Solicitors Regulation Authority with SRA number 615729. Information regarding the data we collect and the rights you have over your data can be found in our Privacy Notice. For further inquiries, please contact dataprotection@jenner.com.

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