ARTICLES - DEBATES most law firms to take a conservative approach and refuse to represent Russia or Russian entities. The consequence of this approach is of course that the right to be heard and access to justice are negatively affected. On the other hand, these delays and uncertainties are also affecting non-Russian parties to arbitral proceedings to which the other party is a Russian entity. 57. The challenges and practical problems discussed above show that the current sanction regime would greatly benefit from enhanced clarity. The situation of pre-arbitral or pre-contentious services remains unclear. Moreover, the conditions in which a counsel may withdraw from the representation of a client in this context is also unclear and the existing case law shows that there is uncertainty. It is even less likely that arbitral tribunals dispose of the necessary tools to rule on counsel withdrawing. There is also a possibility that affected parties will request that counsel is appointed by a third party (Bar association or other) on the basis of the principle of access to justice; the existing case law on such issues shows that there is no straight forward solution. Could one be optimistic and hope that future sanction packages will provide some of the much-needed clarifications? 60 The Paris Journal of International Arbitration 2023‑1