Additional EU, UK and US sanctions relating to Russia
In the last 48 hours, the EU, UK and US have announced additional tranches of sanctions against Russia in response to Russia's military aggression against Ukraine.
We outline the main features of these developments below.
- Ban on SWIFT: First, the EU blocked certain Russian banks' access to SWIFT, namely Bank Otkritie, Novikombank, Promsvyazbank (PSB), Bank Rossiya, Sovcombank, VNESHECONOMBANK (VEB) and VTB BANK, and any legal person, entity or body established in Russia whose proprietary rights are directly or indirectly owned for more than 50 % by such banks. Cutting of certain Russian banks from SWIFT has been expected for some time (see our previous alert here). The prohibition will enter into force on 12 March 2022.
- Prohibition from selling, supplying, transferring or exporting euro denominated banknotes to Russia (including the Government of Russia and the Central Bank of Russia) or for use in Russia. There are certain exceptions related to personal use.
- Prohibition from investing, participating or otherwise contributing to projects co-financed by the Russian Direct Investment Fund (with certain exceptions).
- Prohibition for Russian state-owned media outlets to broadcast in the EU or directed at the EU, and on the facilitation or contributions to broadcasting by these outlets.
As mentioned in our previous alert, on 1 March 2022, the UK imposed shipping sanctions. In brief, the sanctions ban Russian vessels from UK ports and grant authority to detain or control the movement of Russian vessels at UK ports or anchorages. Relevant ships are those that are:
- owned, controlled, chartered or operated by a person/entity designated by the UK or by a person/entity "connected with Russia",
- flying the Russian flag;
- registered in Russa; or
- "specified" by the UK.
Further, the shipping sanctions prohibit the registration of ships that are owned, controlled, chartered or operated by designated persons or persons connected with Russia.
In addition, the UK has imposed restrictions on the provision of financial services for the purpose of foreign exchange reserve and asset management to the Central Bank of Russia, the National Wealth Fund of Russia and the Ministry of Finance of Russia, or a person owned or controlled directly or indirectly by any of those persons, or a person acting on behalf of or at the direction of any of those persons.
The UK has also designated Russian elites on its sanctions list, as well as Belarus individuals (HM Treasury notices are available here, here and here).
During the past 48 hours, there has been yet another wave of sanctions announcements relating to Russia from the US, including:
- Export controls on exports of oil and gas extraction equipment/technology, aimed at targeting Russia's oil refineries.
- Stricter export controls relating to the military as well as the "aerospace, maritime and high-technology sectors" by adding to the so-called BIS Entity List entities that have been involved in or supported the Russian and Belarusian security services, military and defense sectors or research or development efforts, aimed at restricting Russian technical maintenance and innovation.
- Ban on Russian aircraft from entering and using domestic US airspace, including aircraft certified, operated, registered or controlled by any person connected with Russia.
In addition, the US has added numerous individuals and entities to the SDN list, including:
- Russian and Belarusian defence-related entities, including Russian companies that make combat aircraft, infantry fighting vehicles, electronic warfare systems, missiles, and unmanned aerial vehicles for Russia’s military.
- Russian elites who are considered to provide direct or indirect support to the Russian government, including certain of their family members and assets.
- Russian disinformation outlets and individuals who are considered to enable the Russian government's efforts to spread disinformation that "advances Russian strategic objectives and falsely justifies the Kremlin's activities."
White House fact sheets are available here and here. An OFAC press release is available here. Information about the designated individuals and entities is available here.
OFAC has also issued certain Russia-related General Licences during the past days, which provide limited authorizations for activity that would otherwise be subject to sanctions.
Recent Russia related sanctions against Belarus
The EU, UK and US have recently made Russia-related designations of Belarus persons who are considered to have facilitated or benefitted from the Russian military aggression against Ukraine. Information about the recent designations from the EU can be found here. Information about UK designations is available here and in the links above. Details concerning the US designation is largely available in the links above.
In addition, on 2 March 2022, the EU introduced additional trade related restrictions against Belarus in response to the Belarusian involvement in the Russian aggression (press release available here). In short, the restrictions target the trade of goods used for the production or manufacturing of tobacco products, mineral fuels, bituminous substances and gaseous hydrocarbon products, potash products, wood products, cement products, iron and steel products and rubber products. In addition, restrictions were placed on exports of dual-use goods and technology to Belarus, and certain advanced goods and technology which might contribute to Belarus' military, technological, defence and security development (and related services).
Moreover, the US announced on 2 March 2022 stricter export controls on export of items and technology to Belarus (White House fact sheet is available here).
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.