Doing Business With Russia

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Contents

Impacts on US Companies

Exports and Sanctions

Federal

Representative Carolyn B. Maloney, Chairwoman of the House Oversight and Reform Committee, introduced the Federal Contracting for Peace and Security Act. As drafted, the legislation would prohibit the United States from doing business with companies currently operating in Russia. Specifically, the bill would prohibit awards, extensions and renewals of:


  • (i) prime contracts with any company if that company (or any parent, subsidiary, successor entity, or beneficial owner of such company) has done business in Russia during the “covered period of aggression” (beginning, February 21, 2022) against Ukraine, and


  • (ii) prime contracts that include subcontracts at any tier with such companies. The bill would also require termination of existing covered contracts.


To read the bill, follow this link. http://www.govcwiki.org/images/b/b9/Federal_Contracting_for_Peace_and_Security_Act.pdf


The bill includes exceptions for:

  • (i) procurements that benefit Ukraine, either directly or through the efforts of regional allies, and
  • (ii) procurements for humanitarian purposes to meet basic human needs.


States

As of December 13, 2022, Governors in 16 states (including, e.g., California, New York, New Jersey, North Carolina, Washington) are calling for the review and termination of state contracts with Russian entities, and in some instances are proposing to terminate state contracts with companies that do business in Russia. At least 18 states have taken executive action to divest or are considering divestment bills. State legislatures also are considering similar actions aimed at prohibiting state agencies from transacting with Russian entities or companies that do business with Russian entities (e.g., New York, California).


States are considering or have already enacted certification and disclosure requirements for state contractors related to Russia and Belarus.

New York Executive Order 16

For Executive Order 16 see ... http://www.govcwiki.org/index.php?title=New_York_Executive_Order_16