The current article examines the impact of economic sanctions on contractual relationships between parties. This issue is of significant relevance today for several reasons. Firstly, in the case of the Russian Federation, its citizens, and organizations, there has been an unprecedented number of sanctions imposed by foreign countries that hinder commercial activities and require the resolution of arising disputes. Secondly, due to the public nature of sanctions and the limited theoretical development of this topic to date, the application of sanction legislation in commercialdisputes often becomes inconsistent and contradictory.

The article will analyze two primary approaches to the influence of sanctions on contracts and their legal consequences. The first approach suggests treating sanctions as factual circumstances objectively affecting the performance of contractual obligations, without analyzing the legality of such norms’ impact on the contract. As a result, the assessment of such influence is based on lex fori norms regarding force majeure, impossibility of performance, or contract termination. The second approach, on the contrary, regards sanctions as legal norms and assumes their evaluation based on the criteria of international private law (e.g., as overriding mandatory provisions and compliance with the public policy of lex fori).

Due to the limited theoretical development of this subject matter, Russian law often combines these two approaches, leading to unpredictable consequences in the regulation of contractual relationships between parties.