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.

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

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,

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

The United States government has continued to impose numerous economic sanctions and export controls measures following Russia’s invasion of Ukraine.  On February 24, 2022, the US Commerce Department’s Bureau of Industry and Security (BIS) significantly expanded export controls applicable to Russia.  On February 25, 2022, the US Treasury Department’s Office of Foreign Assets Control (OFAC) added Russian President Vladimir Putin and others to the Specially Designated Nationals (SDN) List.  It also imposed significant economic sanctions measures targeting Russia’s financial system — including by imposing sanctions on Russia’s largest financial institutions and limiting the ability of certain Russian state-owned and private entities to raise capital.  Together, OFAC’s actions, which were taken pursuant to Executive Order (EO) 14024 following Russia’s invasion of Ukraine, are estimated to affect nearly 80 percent of all banking assets in Russia.

Finally, on February 26, 2022, the United States and European Union countries, together with the United Kingdom and Canada, announced an agreement to block certain Russian banks from access to SWIFT (with Japan also agreeing the following day), to impose sanctions on Russia’s Central Bank, and to limit the ability of certain Russian nationals connected to the Russian government to obtain citizenship in their countries. They further agreed to ensure effective transatlantic coordination in implementing sanctions, including by sanctioning additional Russian entities and persons, and by working together and with other governments around the world to identify and freeze sanctioned Russian assets.

Continue Reading Biden Administration Imposes Sweeping Financial Sanctions, Export Controls after Russian Invasion of Ukraine

On February 24, 2022, the UK government announced the designation of a further five individuals and six entities under the Russia (Sanctions) (EU Exit) Regulations 2019, following Russia’s invasion of Ukraine.

The sanctions target companies and senior executives operating in Russia’s banking and defence sectors involved in the destabilization of Ukraine or in obtaining a benefit from, or supporting, the Government of Russia.  Three of the five individuals and three of the six companies already were sanctioned by the United States.

Continue Reading Ukraine Crisis: UK Announces Further Tranche of Sanctions Following Russian Invasion

On February 23, 2022, the White House announced sanctions on the Nord Stream 2 pipeline following the announcement that Germany would halt certification of the project. Shortly after, the US Treasury Department’s Office of Foreign Assets Control (OFAC) named Nord Stream 2 AG and its managing director as Specially Designated Nationals (SDNs) pursuant to the Protecting Europe’s Energy Security Act (PEESA) and Executive Order (EO) 14039 of August 20, 2021. OFAC also issued General License No. 4 (GL-4) under EO 14039 authorizing US persons to engage in transactions that are ordinarily incident and necessary to the wind down of transactions involving Nord Stream 2 AG and any entity owned 50 percent or more by it, until March 2, 2022.

The day before, on February 22, 2022, OFAC named more than 40 entities, five individuals, and five vessels as SDNs under EO 14024 of April 15, 2021. The targets included two banks: Corporation Bank for Development and Foreign Economic Affairs Vnesheconombank (VEB) and Promsvyazbank Public Joint Stock Company (PSB). US persons are prohibited from engaging in any transfer, transaction, export, import, withdrawal, or other dealing involving property or interests in property of SDNs, including the two banks and Nord Stream 2 AG, and if in the possession of a US person or otherwise in the United States, such property or interest in property must be blocked and reported to OFAC in no more than ten days. The prohibitions also apply to any legal entity owned 50 percent or more by one or more SDNs, even if not specifically named or included on the OFAC SDN list.

Continue Reading Update: Biden Administration Announces Sanctions on Nord Stream 2, Russian Banks, Sovereign Debt and Other Targets

As the Ukraine Crisis continues to deteriorate following the Russian decision to recognise the Ukrainian regions of Donetsk and Luhansk as independent entities and officially deploying Russian troops, the EU has imposed its first set of sanctions. Also the US and the UK have imposed sanctions. The present blog post addresses the sanctions package that was adopted by the EU late on 23 February 2022. The EU, like other jurisdictions, is expected to issue additional sanctions shortly, and we will keep reporting on those.

The below Q&A provides you with all the information you need to gain a quick understanding of the EU’s Russia sanctions package of 23 February 2022.

Continue Reading Ukraine Crisis: EU imposes broad sanctions package on Russia

On February 22, 2022, UK Prime Minister Boris Johnson announced the designation of five Russian banks and three high net worth individuals under the recently expanded Russia (Sanctions) (EU Exit) Regulations 2019 (see our previous blog post on the UK’s expanded sanctions powers here). The announcement follows the Russian government’s recognition of the so-called Donetsk People’s Republic (DNR) and Luhansk People’s Republic (LNR) and placement of Russian military forces in those territories for purported peacekeeping operations.

The sanctions target Russian banks and high net worth individuals involved in the destabilization of Ukraine or in obtaining a benefit from, or supporting, the Government of Russia.  All three individuals and four of the five banks (with the exception of PJSC Promsvyazbank) already were sanctioned by the United States.

Continue Reading UK Announces First Sanctions Targeting Russian Banks and Oligarchs after Russia Enters Ukraine’s Donetsk and Luhansk Regions

On February 21, 2022, the White House issued a new Executive Order (EO) imposing comprehensive sanctions on the disputed Donetsk and Luhansk regions of Ukraine following President Vladimir Putin’s announcement that Russia would recognize the independence of the so-called Donetsk People’s Republic (DNR) and Luhansk People’s Republic (LNR) and place Russian military forces in those territories for purported peacekeeping operations.

The new EO prohibits:

  • new investment in the DNR or LNR by US persons, wherever located;
  • the importation into the United States, directly or indirectly, of any goods, services, or technology from the DNR or LNR;
  • the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a US person, wherever located, of any goods, services, or technology to the DNR or the LNR; and
  • any approval, financing, facilitation, or guarantee by a US person, wherever located, of a transaction by a foreign person where the transaction by that foreign person would be prohibited if performed by a US person or within the United States.


Continue Reading White House Announces First Sanctions after Russia Enters Ukraine’s Donetsk and Luhansk Regions

On February 2, 2022, HM Treasury’s Office of Financial Sanctions Implementation (OFSI) announced a GBP 36,393.45 monetary penalty against Clear Junction Limited (Clear Junction) for multiple breaches of The Ukraine (European Union Financial Sanctions) (No. 2) Regulations 2014 (the UK Regulations).

According to OFSI’s penalty report, Clear Junction, a fintech company, transferred funds to