Since March 14, 2022, the United Kingdom has continued to introduce and announce new sanctions measures in response to Russia’s invasion of Ukraine. The new UK measures include sanctions enforcement powers under the Economic Crime (Transparency and Enforcement) Act 2022, the designation of hundreds of individuals and entities under the UK’s Russia and Belarus sanctions regimes, the introduction of new general licences, the introduction and announcement of new sanctions measures, and the revision of various guidance documents.
Continue Reading A Summary of New UK Sanctions Enforcement Powers and Further Ukraine-related UK Sanctions on Russia and Belarus
Economic Sanctions
EU Adopts Fourth Package of Sanctions Against Russia
On March 15, the Council of the EU proceeded to adopt the fourth package of sanctions against Russia over the continued military aggression of Ukraine. With these new sanctions, the EU seeks to address potential loopholes under the first three packages, such as by providing clarifications, to restrict certain derogations, and to expand the sanctions’ scope by targeting new sectors. In particular, the new sanctions target the energy sector, although significant carve-outs exist for coal, oil, and natural gas imports.
Following our review of the first, second and third sanctions package, we analyze below the latest restrictive measures which constitute the fourth package of sanctions.
For more information on how these developments could impact your organization, contact a member of Steptoe’s Economic Sanctions team in Brussels.
For additional resources can be found on Steptoe’s “Sanctions against Russia: Implications for Business and International Trade” page.…
Continue Reading EU Adopts Fourth Package of Sanctions Against Russia
What US Financial Institutions Need to Know about FinCEN’s Russian Sanctions Evasion and Ransomware Guidance
On March 7, 2022, the Financial Crimes Enforcement Network (FinCEN) of the US Department of the Treasury published guidance (Guidance) for US financial institutions warning about: (1) efforts of foreign actors to evade expanding US economic sanctions and trade restrictions related to the Russian Federation and Belarus and (2) increased risk of malicious cyber-attacks and related ransomware campaigns, following the invasion of and continued military action in Ukraine. The Guidance provides instructive red flags and related advice for all US financial institutions to evaluate, and provides information of particular relevance for Money Services Businesses (MSBs) and other FinCEN-regulated institutions undertaking transactions in what the agency calls “convertible virtual currency” (CVC).
Most notably, FinCEN strongly encourages US financial institutions that have information about CVC flows, including exchangers or administrators of CVC to: (1) be mindful of efforts to evade expanded US sanctions and export controls related to Russia and Belarus, summarized by Steptoe here; (2) submit Suspicious Activity Reports (SARs) as soon as possible regarding such conduct; (3) undertake appropriate risk-based due diligence of customers, and where required, enhanced due diligence; (4) voluntarily share information with other financial institutions consistent with Section 314(b) of the USA PATRIOT Act; and (5) consider using tools to identify assets that must be blocked or frozen under applicable sanctions.…
Update: EU Adopts Additional Sanctions Against Russia and Belarus over the War in Ukraine
Since the adoption of the first sanctions package against Russia, the Council of the EU and the European Commission (“Commission”) have been working closely together to adopt increasingly severe sanctions to force President Putin back to the negotiating table in view of reaching a ceasefire. Coordination with allies has also been intense. Following our review of the first and second sanctions package, we analyze below the latest restrictive measures.
For more information on how these developments could impact your organization, contact a member of Steptoe’s Economic Sanctions team in Brussels.
For additional resources can be found on Steptoe’s “Sanctions against Russia: Implications for Business and International Trade” page.…
Round Up of New UK Sanctions and Export Controls on Russia and Belarus
By Alexandra Melia on
Since March 8, 2022, the United Kingdom has continued to introduce and announce new sanctions and export controls measures in response to Russia’s invasion of Ukraine. The new UK measures include the designation of hundreds of individuals, the introduction of new sanctions measures under the sixth amendment to The Russia (EU Exit) (Sanctions) Regulations 2019 (Russia Regulations), amendments to VTB Bank general licence INT/2022/1272278, removal of Belarus from nine open general export licences (OGELs), and the announcement of the UK’s intention to phase out Russian oil imports by the end of 2022.
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Continue Reading Round Up of New UK Sanctions and Export Controls on Russia and Belarus
A Summary of New Ukraine-related US Sanctions and Export Controls on Russia and Belarus
Since February 21, 2022, the United States has joined a coalition of countries imposing sanctions in response to Russia’s invasion of Ukraine. New US sanctions and export controls are wide ranging and complex, significantly impacting trade and related financial transactions between the US and Russia, as well as Belarus. They also affect transactions and exports from outside the United States in many areas of commerce. The following is a high-level overview of recent US legal developments as of March 8, 2022.
For more information on how these measures could impact your organization, contact a member of Steptoe’s Economic Sanctions and Export Controls teams.
Additional resources can be found on Steptoe’s “Sanctions against Russia: Implications for Business and International Trade” page.…
Update: OFSI Publishes Updated Russia Guidance; Issues New General Licences; and UK Amends Draft Economic Crime Legislation to Move “Harder and Faster” with Sanctions
By Alexandra Melia on
On March 4, 2022, HM Treasury’s Office of Financial Sanctions Implementation (OFSI) published an updated version of its Russia guidance and issued two new general licences permitting the wind down of positions with Sberbank and involving Bank Otkritie, Promsvyazbank, Bank Rossiya, Sovcombank, and VEB. The UK government also put forward a series of amendments to the Economic Crime (Transparency and Enforcement) Bill proponents say is needed to crack down on corrupt elites and ramp up pressure on President Putin’s regime.
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Continue Reading Update: OFSI Publishes Updated Russia Guidance; Issues New General Licences; and UK Amends Draft Economic Crime Legislation to Move “Harder and Faster” with Sanctions
Update: New UK Russia Sanctions Legislation Comes into Effect, Suspension of Export Licences for Dual-Use Items to Russia, Additional Designations and New General Licences
By Alexandra Melia on
On March 1, 2022, four new amendments to The Russia (Sanctions) (EU Exit) Regulations 2019 (Russia Regulations) were laid before parliament and came into immediate effect. The amendments revise the financial and investment restrictions provisions contained in Part 3, Chapter 2 and the trade sanctions provisions set out in Part 5. New restrictions also have been introduced banning Russian ships from UK ports under Part 6 and introducing restrictions on the provision of financial services for the purpose of foreign exchange reserve and asset management.
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Continue Reading Update: New UK Russia Sanctions Legislation Comes into Effect, Suspension of Export Licences for Dual-Use Items to Russia, Additional Designations and New General Licences
Update: UK Announces New Sanctions on Russian Banks, Issues General Licences
By Alexandra Melia on
Posted in Economic Sanctions, UK Sanctions
On February 28, 2022, the UK government announced the designation of a further three Russian banks under the Russia (Sanctions) (EU Exit) Regulations 2019 (Russia Regulations) determined to be involved in obtaining a benefit from, or supporting, the Government of Russia. Two of the three banks already were sanctioned by the United States. Additional banks,…
Update: EU Adopts Far-Reaching Sanctions following Russian Invasion of Ukraine
Following Russia’s invasion of Ukraine, the EU has adopted a much more severe sanctions package against Russia than the measures adopted on February 23, 2022 (see our previous previous blog post). The new measures provide for various restrictions, including additional targeted restrictions against specified individuals; expanded financial measures aiming at cutting Russia’s access to the EU capital markets; trade restrictions targeting the energy and aviation sectors and banning most exports of dual-use items, as well as certain semiconductors and cutting-edge technologies from the EU to Russia.
The key aspects of the new sanctions imposed by the EU are summarized below. Unless otherwise specified, references to Annexes in the below overview refer to Annexes to Council Regulation (EU) No 833/2014 (as amended or inserted by Council Regulation (EU) 2022/328 of February 25, 2022).…
Continue Reading Update: EU Adopts Far-Reaching Sanctions following Russian Invasion of Ukraine