Additional US, EU and UK sanctions against Russia
In view of the gravity of the Russian aggression against Ukraine, the US, the EU and the UK have adopted additional sanctions against Russia since our previous update on 5 April 2022.
We highlight the main points of these developments below.
On 6 and 7 April, the US adopted new sanctions against Russia, including prohibitions on all new investments in Russia by US persons, wherever located. The new sanctions also include:
- A prohibition on US persons facilitating foreign persons' transactions with Russia.
- The addition of Sberbank and Alfa-Bank and a number of their subsidiaries to the SDN List. Certain energy-related and wind-down transactions with these entities are permitted until June 2022.
- The addition of Alrosa, the world's largest diamond mining company, to the SDN list, along with Russia's largest shipbuilding company, United Shipbuilding Corporation.
- The addition of 25 individuals to the SDN list, including family members of Vladimir Putin and Russian Foreign Minister Sergey Lavrov, as well as remaining Russian Security Council members. Many of these individuals have previously been sanctioned by the US's international partners, including Canada, the EU, Japan, New Zealand, Australia, and the UK.
On Friday, 8 April 2022, the EU adopted its fifth sanctions package against Russia in response to Russia's military aggression against Ukraine.
In respect of sectoral sanctions, the new EU sanctions package broadly includes the following measures:
- Port access: Prohibition from providing access after 16 April 2022 to ports in the EU to vessels registered under the flag of Russia (and to vessels that have changed their Russian flag or registration to the flag or register of other states after 24 February 2022). Certain exceptions are available. Derogations may be granted for port access that is deemed necessary for specified purposes (such as the purchase, import or transport of certain goods into the EU).
- Road transport: Prohibition for any transport undertaking established in Russia to transport goods by road in the EU, including in transit. There are certain exceptions available. Further, derogations may be granted for transports that are deemed necessary for certain purposes (such as the purchase, import or transport of certain goods into the EU).
- Additional export restrictions: Prohibitions on the sale, supply, transfer or export to any person in Russia or for the use in Russia of:
- Jet fuel and certain fuel additives (as listed in Annex XX); and
- Certain goods and technology which could contribute in particular to the enhancement of Russian industrial capacities (as listed in Annex XXIII).
- Additional items have been added to the list of controlled items which might contribute to Russia’s military and technological enhancement or the development of its defence and security sector (as listed in Annex VII).
- There are restrictions on the provision of related technical and financial assistance.
- Additional import restrictions: Prohibitions on the purchase, import, or transfer into the EU, if originating in Russia or exported from Russia, of:
- goods which generate significant revenues for Russia, including (among other things) wood, cement, fertilisers and seafood (as listed in Annex XXI); and
- coal and other solid fossil fuels (as listed in Annex XXII).
- There also restrictions on the provision of related technical and financial assistance.
- Various additional measures intended to strengthen existing sanctions and close loopholes, broadly including:
- Prohibitions on the award and continued execution of public or concession contracts to Russian persons and entities. Exceptions and derogations are available.
- Prohibitions on the provision of high-value crypto-asset services to Russian persons and entities
- Extensions of the prohibitions on the export of euro-denominated banknotes and on the sale of euro-denominated transferrable securities to all official currencies of EU member states
- Various prohibitions related to the provision of services related to trusts that have a Russian national or an entity established in Russia as trustor or beneficiary
- Restrictions on the provision of support, including financial support, to Russian publicly owned or controlled entities under EU, Euratom and member state programmes.
- In addition, there are certain changes to exemptions from the prohibition to engage in transactions with certain (listed) state-owned entities and their subsidiaries.
Further details on the new measures, including wind-down/transitionary periods (where available) and other exceptions and derogations, may be found in Council Regulation (EU) 2022/576 (amending Regulation (EU) 833/2014). The new EU sectoral measures have not yet been transposed into Norwegian law.
Moreover, the fifth EU sanctions package includes targeted sanctions against additional individuals and entities.
Individuals that are now subject to asset freezes are additional high-ranking Kremlin officials, oligarchs and other prominent businesspeople, as well as those engaged in propaganda activities. Targeted entities include those form the Russian financial, military industrial and transport sectors, including four major Russian banks (i.e. Bank Otkritie, Novikombank, Sovcombank, and VTB).
Further information, including identifying details of the targeted individuals and entities, may be found in Council Implementing Regulation (EU) 2022/581 (implementing Regulation (EU) 269/2014).
Since our last update, the UK has added several Russian individuals and entities to its asset freeze sanctions list. Notable examples include Sberbank and Credit Bank of Moscow, as well as additional oligarchs, businesspeople and some of their family members. An overview of all OFSI notices, containing identifying information about the designated individuals and entities, is available here. An updated and consolidated version of the UK sanctions list can be found here. General licenses that authorise certain transactions with designated parties are available here.
In addition, the UK has announced "a significant ratcheting up" of UK sanctions on Russia. Broadly, the announced changes are described to include:
- Ban on all new outward investment to Russia.
- UK to end all imports of Russian coal (and oil, as previously announced) by end of 2022, and end imports of gas as soon as possible thereafter.
- Ban on the export of key oil refining equipment and catalysts from sometime this week.
- Ban on imports of iron and steel products.
- New restrictions on the ability to acquire the UK's quantum and advanced material technologies.
WR Sanctions Alerts provide you with updates on material developments in the country-specific sanctions programmes implemented by the US, the UN, the UK, the EU and Norway. We will not provide updates on mere prolongations, without material changes, of existing sanctions programmes, nor on any listings or de-listings of individuals/entities placed on implemented sanctions lists. Please note that the WR Sanctions Alerts are provided as general information and do not constitute legal advice.