This guidance does not constitute legal advice. To the extent that you have any questions arising out of the guidance, please speak to a member of the Orrick team who will be happy to assist.

The invasion of Ukraine by Russia has had a profound impact across the globe. One of the results of the invasion has been the swift and severe imposition of sanctions by various nations on Russian individuals and entities, in particular those with close ties to the Russian state. The Russian government has also established special procedures for shares in non-Russian companies held by Russian residents.

Many technology companies have some level of exposure to Russia – whether as a result of receiving investment which is connected with Russia (e.g., by venture capital funds backed or affiliated with Russian linked general or limited partners^[1]), having counterparties (including Russian banks)^[2] established in Russia (or which are owned by Russian interests) or because they have Russian employees and/or option holders. Exposure to Russia can also be in the form of businesses with operations in Russia or which export to Russia. Accordingly, the imposition of sanctions is causing VC-backed companies both legal and practical headaches. With the sanctions against Russia unlikely to be removed anytime soon – the following is a guide for VC-backed companies to help navigate the sanctions imposed in the U.S., UK and EU.

The sanctions regimes impose significant consequences if they are...

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