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Insight

New UK, EU and US sanctions on Russia

New UK, EU and US Sanctions on Russia and Belarus update as of 16 March 2023

With the rapid expansion of UK, EU and US sanctions on Russia and Belarus in recent weeks - and with more in the regulatory pipeline - we set out:

  1. What's New (to 16 March)
  2. A 5-step checklist for assessing how your activities may be affected
  3. A Sanctions Summary

WHAT’S NEW

G7

The G7 has established the ‘Russian Elites, Proxies and Oligarchs (REPO) Task Force’ for coordinating the enforcement of Russia sanctions, chaired by the US in the first year. It seeks to improve information sharing and sanctions enforcement directed at countries and firms suspected of helping Russia in Ukraine through circumvention of sanctions.
On 10 March 2023, the task force (made up of representatives from the EU, UK, US, Canada, France, Germany, Italy, Japan and Australia) made a Joint Statement and issued a Global Advisory on Russian Sanctions Evasion. It says members of the task force have:

  • blocked or frozen more than $58 billion worth of sanctioned Russians’ assets;
  • immobilised Russian Central Bank and Russian National Wealth Fund assets;
  • seized or frozen luxury real estate and other luxury assets owned, held or controlled by sanctioned Russians;
  • seized, frozen or detained yachts and other vessels owned, held or controlled by sanctioned Russians, and conducted asset tracing activities to identify, locate, freeze and seize yachts, aircraft and other property;
  • convened 6 multilateral meetings, shared information and taken collective action to restrict sanctioned Russians’ access to the global financial system;
  • investigated and countered Russian sanctions evasion, including attempts to hide or obfuscate assets, illicit cryptocurrency and money laundering schemes, illicit Russian defence procurement and sanctioned Russians’ use of financial facilitators;
  • led and coordinated sanctions enforcement efforts with international partners and counterparts, such as the European Commission’s Freeze and Seize Task Force;
  • updated, expanded and implement REPO members’ respective legal frameworks that enable the freezing, seizure, forfeiture and / or disposal of assets; and
  • effected the first forfeiture of assets of a sanctioned Russian, paving the way for the transfer of $5.4 million in funds as foreign assistance to Ukraine.

UK

  • On 16 March, OFSI updated its Enforcement and Monetary Penalty guidance to include details on its approach to assessing breaches of financial sanctions where an incorrect assessment of ownership and control of an entity is relevant to the commission of the breach. The updated guidance sets out examples and a principles-based approach for conducting due diligence and making assessments.
  • On 15 March, the UK Supreme Court held that the Law Debenture Trust Corporation plc, acting on behalf of Russia, is not entitled to a summary judgment in its contractual dispute with Ukraine relating to a loan made by Russia to Ukraine. The loan took the form of Eurobonds with a nominal value of US $3 billion and interest at 5% per annum to Russia, issued by Ukraine in 2013. Ukraine's defences to payment of the Notes included that the Notes were procured by duress arising from unlawful and illegitimate threats and pressure, including trade sanctions. On this point, the Supreme Court said: "a contract is voidable if it was induced by illegitimate pressure." The Supreme Court held that Ukraine should be permitted to defend the claim on the ground of duress, but only to the extent that it is based on duress of the person or of goods resulting from Russia's alleged threatened use of force. Ukraine's defences on the issues of capacity, authority and countermeasures should be struck out.
  • On 14 March 2023, the High Court rejected the first challenge to a UK sanctions listing, brought by a Belarus technology company,  LLC Synesis.  The High Court rejected its application under the Sanctions & Anti-Money Laundering Act on the grounds that the decision not to de-list it was not unreasonable or disproportionate.  The High Court found that the threshold for UK listing, ie “reasonable grounds to suspect” that the person fulfils the listing criteria, is a well-established test in UK law. It means the decision-maker must consider all material or information known to him or which should have been within his knowledge following reasonable inquiry.  It does not require a finding of fact but the assessment of available information and material. The standard of review by the Court is not to stand in the decision-maker’s shoes but to examine whether the Government’s decision was based on no evidence or was irrational, with a broad margin of appreciation in a context of expert Government decision-making.
  • On 13 March, the UK government announced a £50 million Economic Deterrence Initiative to strengthen the implementation and enforcement of UK sanctions, including by tackling sanctions evasion.
  • OFSI has updated its "UK Maritime Services Prohibition and Oil Price Cap" industry guidance following the introduction of the price cap on refined Russian oil products on 5 February 2023 and the associated wind down period.
  • On 24 February 2023, the House of Commons objected to the "Seizure of Russian State Assets and Support for Ukraine Bill". The Bill was introduced by Sir Chris Bryant, under the "Ten Minute Rule" and had its second reading (i.e. this was the first opportunity for MPs to debate the main principles of the Bill). Bills introduced under the "Ten Minute Rule" rarely reach the statute books, but this Bill is notable in the broader context of the seizure of Russian assets. The next sitting of the House of Commons to consider the Bill will be on 17 March 2023.

EU

  • On 13 March, the EU Parliamentary Research Service published a briefing on EU sanctions on Russia. It covers:
    • a timeline and overview of Russia sanctions adopted by the EU from 2014 to February 2023, including description of the adopted measures and the relevant sanctions frameworks, their legal basis, renewal patterns and scope;
    • the oil cap and oil embargo, including as assessment of the policy, its impact on EU imports and the response from Russia;
    • sanctions effectiveness, as determined by the degree of multilateral alignment and the efficacy of enforcement;
    • the economic impact of sanctions, specifically in terms of GDP, unemployment, inflation, exchange rate, trade and Russian and foreign companies; and
    • “demands” of the European Parliament, including:
      • further outreach to countries that have not adopted sanctions on Russia;
      • the active prevention, investigation and prosecution by Member States of sanctions circumvention and the establishment of a legal regime for the confiscation of frozen assets that will allow for their use to reconstruct and compensate Ukraine;
      • the development of an EU legal framework for the designation of states as sponsors of terrorism and states which use means of terrorism;
      • the extension of the EU Global Human Rights Sanctions Regime to include acts of corruption and the designation of those responsible for high-level corruption in Russia and Belarus; and
      • the strict enforcement of all sanctions and an impact assessment on the effect of sanctions on Russia’s war effort and sanctions circumvention.
  • On 10 March, it was reported that French lawyers Avocats Ensemble (ACE), which represents the French business bar, filed an application for the annulment of the EU's ban on the provision of legal advisory services to the Government of Russia or people, entities or bodies established in Russia. The ban was introduced with the EU's 8th package of Russia sanctions.
  • The Danish Business Authority is reported to be examining the Russia-related business activities of Rockwool, an insulation manufacturer, with regard to EU sanctions on Russia.
  • On 20 February 2023, the Dutch government announced proposals supported by a dozen EU Member States, to establish a centralised EU sanctions watchdog to tackle mass circumvention of the bloc’s sanctions against Russia centrally from Brussels. The proposals would strengthen sanctions enforcement by promoting better information sharing between Member States and the EU on sanctions circumvention and by using diplomatic outreach to promote sanctions compliance and counter circumvention.

US

  • On 10 March, the DOJ announced the unsealing of a warrant for the seizure of a US-manufactured Boeing 737-7JU aircraft worth $25 million and owned by Russian energy company PJSC Rosneft Oil Company. The US District Court for the Eastern District of New York authorised the seizure, finding probable cause that the aircraft was subject to seizure based on violations of the Export Control Reform Act (ECRA) and US sanctions on Russia.
  • ‚ÄčOn 3 March, OFAC, BIS and the DOJ published a Compliance Note on 'cracking down on third-party intermediaries used to evade Russia-related sanctions and export controls'. The note identifies possible circumvention techniques, including the use of "transhipment points" and obscuring identities of Russian end-users.

2.         YOUR 5-STEP CHECKLIST

1. Which countries’ sanctions apply to your activities?

The UK, EU, US and other countries’ sanctions typically must be observed if there is a sufficient nexus to confer jurisdiction, that is if:

  • their nationals (individuals) are involved, wherever they are in the world;
  • any part of a transaction is conducted within their territory or airspace; and
  • legal entities incorporated or constituted under their law, including foreign branches are involved; or
  • with respect to US sanctions, if a transaction is conducted in US dollars or clears through the US financial system, or data is routed through servers in the US, or where US products, technology or services located in a third country are re-exported or are procured with intent or reason to know they will be routed to a sanctioned country or person.

UK sanctions may also apply to non-UK persons outside the UK if there is a sufficient nexus.  This will depend on the facts of each case but could include:

  • transactions using clearing services in the UK;
  • actions by a local subsidiary of a UK company;
  • actions directed from within the UK; and/or
  • financial products or insurance bought on UK markets but held or used overseas.

Additionally, US ‘secondary sanctions’ may be applied to non-US persons outside the US in the absence of any US nexus if a transaction involves sanctionable conduct that would be prohibited to a US person and that is determined by the US authorities to be a ‘significant’ transaction or otherwise provides material support to a sanctioned party.  Whether a transaction is ‘significant’ is based on a number of open-ended criteria e.g. the size, number and frequency of transactions.

2. Are any of your business partners subject to an asset freeze?

The UK, EU, US and others have imposed asset freezes (‘blocking sanctions’ in US terms) on most Russian banks and strategic industries (e.g. defence, transport, research, media and aerospace), and senior individuals in the Russian government, state-owned corporations and major businesses, including family members, and they are continuing to add new names to their national lists of such ‘designated persons’.

An asset freeze generally requires those within the scope of the national sanctions, as described at step 1 (above), to:

  • freeze any assets of the designated parties that they may hold and to report these to their authorities;
  • not make any funds or economic resources available to them, directly, indirectly or for their benefit;

In addition, US restrictions go further and in effect also prohibit all transactions with the designated (i.e. listed) party.

The same restrictions also apply to any non-designated entity that is:

  1. ‘owned’ by a designated party or parties. The US threshold is 50% or more, while the UK and EU thresholds are ‘more than 50%’. The US and the EU (in guidance) consider the criterion met if the aggregated ownership of two or more designated parties exceeds the threshold. The UK (also in guidance) recognises aggregated ownership only if there is evidence of a joint arrangement between two or more designated parties; or 
  2. (in the UK/EU, not the US) ‘controlled’ by a designated entity (i.e. able to ensure the affairs of the undesignated entity are conducted in accordance with their wishes, for example through controlling a majority of voting shares or having the right to appoint or remove a majority of the board of directors).

It is often challenging to reach a definitive view of whether this ‘control’ criterion is applicable, for example if a majority shareholder becomes sanctioned and passes some of their shares to unsanctioned family members or to business associates. If you would like assistance on these issues, do get in touch. 

If you do business with Russia or Belarus, you should screen your business partners - banks, suppliers, customers, distributors – against the applicable national sanctions lists and, given the current rapid pace of developments, set up alerts for new designations, in order to be able to identify any relevant new sanctions measures without delay. In some instances, the measures include exceptions or general licences that provide for a wind-down period, but others may have immediate effect. Note that asset freezes on Russian banks may prevent you from receiving or making payments to business partners or to employees.

It should also be noted that, while there are many similarities between the respective national lists, there are also significant differences. For example, a Russian company might be subject to EU sanctions but not to UK or US sanctions. In such cases, it may be possible for UK persons to do business with the Russian company provided that there is no EU nexus (as described in step 1 above), including that any EU nationals are recused.

3. Are any of your activities affected by other financial sanctions?

Short of an asset freeze, sanctions measures may restrict or prohibit:

  • granting new loans or credit (including payment terms);
  • sanctioned banks from clearing payments in certain currencies;
  • dealing in transferable securities and money market instruments issued by sanctioned parties;
  • the size of bank deposits by nationals of sanctioned countries;
  • the access of sanctioned banks to the SWIFT messaging systems;transactions with the Russian Central Bank and certain State-owned enterprises;
  • new investment or acquisitions and the provision of investment services.

The screening of your business partners, including banks, should check for the application of any of these restrictions. However, note that there may be exceptions, grounds for licensing and/or wind-down periods.

4. Are your products or services restricted?

Trade sanctions may restrict or prohibit:

  • the sale, supply, transfer or export to Russia/Belarus, directly or indirectly, of certain goods and technology beyond those that are normally subject to export controls. This generally includes related financial services, brokering and technical assistance (e.g. repair, maintenance). The restrictions may be focused on only certain designated entities. There may be exceptions, grounds for licensing and/or wind-down periods;
  • the import, purchase, transport or insurance of certain goods or technology from, or originating in, Russia/Belarus – notably including oil - with similar related provisions as those for exports;
  • accounting, tax consulting, business and management consulting, public relations, architectural, engineering, IT consultancy, legal advisory and trusts services;
  • closure or airspace and ports to aircraft and ships;
  • more wide-ranging embargoes on most finance and trade with certain regions (previously Crimea, now extended to the occupied areas of Donetsk and Luhansk);
5. Do you have the right measures in place to mitigate your risks?

Given the evolving and expanding scope of sanctions, have you audited your compliance programmes and contractual commitments to make sure you are mitigating any risks?  For example, have you:

  • Updated your compliance policies and procedures, ensuring they are proportionate and workable?
  • Reviewed your technology infrastructure to support your day-to-day compliance (e.g. with on-boarding clients and service providers or providing IP/geolocation support for your KYC process)?
  • Tailored and updated your training for your compliance leads and others across your business?
  • Reviewed whether your contracts enable you (or the counterparty) to suspend or terminate it without liability or serious risk of challenge, whether through a specific sanctions provision or other clauses such as the material adverse change clause?

3.         YOUR SANCTIONS SUMMARY

We set out below a high-level overview of the current UK, EU and US sanctions in addition to asset freezes (as set out above).

Please note that exceptions, grounds for licensing and wind-down periods often apply to specific sanctions; if you would like an analysis as to the legality of a particular transaction, trade or matter, do get in touch. 

UNITED KINGDOM

The UK has announced its intention to introduce certain new sanctions measures which it has not yet implemented, including:

  • Export bans on every item Russia has been found using on the battlefield in Ukraine, including aircraft parts, radio equipment and electronic components;
  • Import bans on 140 goods, including iron and steel products processed in third countries, aircraft parts, radio equipment, and electronic components that can be used by the Russian military industrial complex, including in the production of UAVs;
  • The extension of existing measures against Crimea and the non-government-controlled areas of Donetsk and Luhansk to the non-government-controlled areas of Kherson and Zaporizhzhia;
  • A ban on the provision of transactional legal advisory services (to cover “certain commercial and transactional services and hamper Russia’s businesses’ ability to operate internationally”);
  • Restrictions to cut off wealthy Russians’ access to UK banks including a £50,000 limit on bank accounts and
  • The suspension of the process by which actions taken to manage the orderly failure of Russian banks are recognised under the laws of the UK, in cases where the bank is a sanctioned entity.

Financial services:

  • A ban on dealing with transferable securities and money market instruments or issuing new loans or credit with a maturity exceeding 30 days to:
    • where issued since 2014, an entity listed in Schedule 2 (including Sberbank, VTB Bank, Gazprombank, VEB, Rosneft, Transneft and Gazprom Neft) or their non-UK subsidiaries;
    • where issued since 1 March 2022, UK subsidiaries of Schedule 2 entities; a “person connected with Russia” (an individual located in or ordinarily resident in Russia, or an entity domiciled, incorporated or constituted under the law of Russia); an entity owned by or acting on behalf/at the direction of such as person; or the Government of Russia;
    • where issued on or after 16 December 2022,  by a person not connected with Russia where the purpose of the loan or credit is to make a new investment in Russia;
  • A ban on UK credit or financial institutions establishing or continuing a correspondent banking relationship with, or processing sterling payments to from or via, a designated person;
  • A ban on financial services for foreign exchange reserve and asset management to the Central Bank of the Russian Federation, the Russian National Wealth Fund and the Ministry of Finance, and persons owned or controlled directly or indirectly by them or acting on their behalf or direction;
  • A ban on new investment, specifically the:
    • direct acquisition of any ownership interest in Russian land and entities connected with Russia;
    • indirect acquisition of any ownership interest in Russian land and entities connected with Russia for the purpose of making funds or economic resources available to, or for the benefit of, persons connected with Russia;
    • direct or indirect acquisition of any ownership interest in entities with a place of business in Russia (which are not persons connected with Russia) for the purpose of making funds or economic resources available (directly or indirectly) to, or for the benefit of, persons connected with Russia;
    • establishment of joint ventures with a person connected with Russia;
    • opening of representative offices and establishing branches and subsidiaries in Russia; and
    • provision of investment services directly related to the above; and
  • Selected Russian banks removed from the SWIFT messaging system.

Trade:

Exports
  • A ban on the export, supply and delivery, and making available of the following goods and technology, and related services, to Russia:
    • military and internal repression items;
    • advanced technology items: dual-use, ‘critical industry’, special materials, quantum computing, aviation, maritime and space;
    • a wide range of items mainly for the manufacturing sector and luxury items;
    • infrastructure-related, energy-related and oil refining items, and jet fuel;
    • sterling or EU denominated banknotes
Imports
  • A ban on the import or acquisition of the following goods and technology consigned from or originating in Russia, as well as related services:
    • oil and oil products, LNG, and coal and coal products;
    • iron and steel items;
    • a range of materials and manufactured items generating revenue for Russia;
    • gold and gold jewellery; and
    • a 35% tariff on imports of certain goods originating in Russia and Belarus.
Services
  • A ban on the provision of the following services:
    • maritime transport, insurance and other financial services for ships carrying Russian crude oil/refined oil products to or between third countries, unless the crude oil/refined oil products has been sold below a specific price cap;
    • trust services, accounting, business and management consulting, public relations, advertising, architectural, auditing, engineering and IT consultancy and design services to persons connected with Russia;
    • social media, internet services and app stores are required to block content from RT and Sputnik; and
    • a ban on all Russia-owned or operated aircraft and ships from UK airspace, landings, and ports, and on aviation and shipping technical assistance to, or for the benefit of, designated people/entities.
Crimea, Donetsk and Luhansk
  • A ban on:
    • finance and investment;
    • the export, supply and delivery, and making available of the following goods and technology, and related services: military, infrastructure-related goods and tourism services;
    • all imports.

Belarus

  • Restrictions on dealing with transferable securities or money-market instruments;
  • A ban on providing insurance and re-insurance to the Belarusian Government and Belarusian public bodies and agencies;
  • A ban on the export, supply and delivery, and making available of the following goods and technology, and related services, to Belarus:  military and internal repression; dual-use, critical industry,  quantum computing, advanced materials, certain minerals, oil refining items and luxury goods;
  • A ban on the import or acquisition of the following goods and technology consigned from or originating in Belarus, as well as related services: oil products, iron, steel, potash and tobacco; and
  • Ban on Belarusian and other specified ships from entering UK ports, and aircraft from UK airports.

EUROPEAN UNION

Financial services:

  • Banking:
    • A ban on the provision of SWIFT services to most Russian banks;
    • A ban on transactions with Russia's central bank;
    • A ban on deposits from Russian nationals or legal persons if the total value exceeds 100,000 EUR;
    • A ban on the provision of crypto-asset wallet, account or custody services to Russian persons and residents; and 
    • A ban on the sale of banknotes and transferrable securities denominated in any official currencies of the EU member states.
  • Investment:
    • A ban on investment, participation or contribution to projects co-financed by the Russian Direct Investment Fund;
    • From 18 March 2023, the Russian Regional Development Bank will be subject to a full transactional ban for contracts concluded before 17 December 2022;
    • A ban on providing credit rating services, or access to any subscription services in relation to credit rating activities, to any Russian person, resident, entity or body;
    • A ban on new investments in the Russian energy and mining sectors (except certain metals);
    • A ban on dealing in transferable securities (including crypto-assets), or money-market instruments of any maturity, issued by certain listed Russian entities and on new loans and/or credit to them;
    • A ban on the listing and provision of services in relation to shares of Russian state-owned entities on EU trading venues;
    • A ban on EU central securities depositories services for transferable securities issued after 12 April 2022 to any Russian persons;
    • The Russian Maritime Register of Shipping has been added to the list of state-owned enterprises subject to financial restrictions; 
    • The exclusion of all financial support to Russian public bodies.

Trade:

Exports
  • A ban on the export, supply and delivery, and making available of the following goods and technology, and related services, to Russia:
    • military, internal repression, dual-use and advanced technologies including quantum computers, high-end electronics, software, sensitive machinery and transportation;
    • energy industry (except nuclear and energy transport), oil refining, coal and coking coal; 
    • aviation, jet fuel and space;
    • luxury goods;
    • maritime navigation; 
    • items which may contribute to Russia’s military, industrial and technological enhancement including coal, certain electronic components, chemicals and torture goods;
Imports
  • A ban on the import or acquisition of the following goods and technology consigned from or originating in Russia (as well as related services):
    • oil and refined products. Direct imports of crude oil by pipeline are permitted for the time being but such oil, and products refined from it, may not be transferred to other Member States or third countries.
    • There is an exception for seaborne products that transit Russia but originate in a third country and are owned by non-Russians; 
    • coal and other solid fossil fuels;
    • products including: wood, cement, fertilisers, seafood, liquor, iron and steel, machinery and appliances, wood pulp and paper, cigarettes, plastics, vehicles, textiles, footwear, leather, ceramics, certain
    • chemical products, cosmetics and elements used in the jewellery industry; bitumen and related materials like asphalt; and synthetic rubber and carbon blacks;
    • Russia-origin gold (including jewellery) if it has been exported from Russia into the EU or to any third country; and
    • A ban on the participation of Russian companies in public procurement in member states.
Services
  • A ban on the provision of the following services:
    • Maritime transport and insurance to ships carrying Russian crude and petroleum crude oil/ refined oil products to third countries, with an exemption for the provision of insurance where the crude oil/ refined oil products has been sold below a specific price cap;
    • listed Russian state-owned broadcasters broadcasting in the EU, and advertising products or services in any content broadcast by these entities;
    • provision of architectural and engineering services, IT consultancy services, legal advisory services, accounting, auditing, bookkeeping or tax consulting services, business and management consulting, public relations, advertising, market research and public opinion polling services, as well as product testing and technical inspection services to the Government of Russia, or entities established in Russia;
    • all transactions with certain state-owned companies including the Russian Maritime Shipping Register; and
  • A ban on EU nationals holding any posts on the governing bodies of any Russian state-owned or controlled legal persons, entities or bodies.
Donetsk, Luhansk, Zaporizhzhia and Kherson
  • With respect to the occupied areas of the oblasts:
    • an import ban on all goods and related services;
    • restrictions on trade and investment related to certain economic sectors;
    • a prohibition on supplying tourism services; and
    • an export ban on goods and technology suited to the transport, telecommunications, energy or oil, gas and mineral sectors; and a ban on the provision of technical assistance, brokering, construction or engineering services to infrastructure in the regions and within the aforementioned sectors.
Access
  • The closure of  EU airspace to all Russian-owned, Russian registered or Russian-controlled aircraft;
  • A prohibition on providing access to vessels registered under the flag of Russia, or Russian-operated vessels, to EU ports; and
  • A ban on any Russian transportation of goods by road within the EU.

Belarus

  • A ban on the sale of banknotes and transferrable securities denominated in any official currencies of the EU member states, or to any natural or legal person, entity or body in Belarus;
  • A ban on transactions with the Central Bank of Belarus related to the management of reserves or assets;
  • A block on SWIFT services to Belinvestbank, Belagroprombank, Bank Dabrabyt, the Development Bank of the Republic of Belarus, as well as their Belarusian subsidiaries;
  • Financial and air-traffic sanctions;
  • A ban on the listing of, and provision of services in relation to, shares of Belarus state-owned entities on EU trading venues;
  • A €100,000 cap on deposits from Belarusian nationals, residents, or entities established in Belarus;
  • A ban on the sale of euro-denominated transferable securities issued after 12 April 2022 to Belarusian nationals, residents, or entities established in Belarus;
  • A ban on the provision of services by EU central securities depositories to Belarusian nationals, residents, or entities established in Belarus;
  • A ban on any Belarusian transportation of goods by road within the EU;
  • A ban on the sale, supply, transfer or export, directly or indirectly, to or for use in Belarus and related services of the following goods and technology: military and internal repression, dual-use and a range of materials, manufactured goods and machinery; and
  • An expansion of existing bans on imports from Belarus into the EU of goods for the following products and related services: tobacco, minerals, wood, cement, iron and steel, rubber, and potash.

UNITED STATES

Financial services:

  • A ban on all transactions involving the Central Bank of the Russian Federation; the National Wealth Fund of the Russian Federation; and the Ministry of Finance of the Russian Federation, and dealing in bonds issued by them after 1 March 2022;
  • A ban on dealing in new debt of over 14 days maturity and new equity of strategic entities: Sberbank, AlfaBank, Credit Bank of Moscow, Gazprombank, Russian Agricultural Bank, Gazprom, Gazprom Neft, Transneft, Rostelecom, RusHydro, Alrosa, Sovcomflot, and Russian Railways;
  • Selected Russian banks removed from the SWIFT messaging system;
  • All forms of new investment in Russia, including the formation of joint ventures and all loans for commercial purposes to persons located in Russia;
  • The export, re-export, sale or supply of USD denominated banknotes to the Russian government or any person located in Russia.

Trade:

Exports
  • A ban on the export, supply and delivery, and making available of the following goods and technology, and related services, to Russia:
    • military and dual-use items, and a wide range of advanced technologies, encryption products and software including updates;
    • a wide range of items which could contribute to the enhancement of Russian industrial capacities including containers, machinery, tools, industrial engines and motors, goods vehicles, and equipment for refrigeration, elevators, construction, printing, textiles, valves, bearings, seals, electrical, radio, railways and testing; and luxury goods
  • The expansion of controls on US-origin and foreign-made (non-US) items and direct products of US technology for listed Russian military end use/r and military-intelligence end use/r;
  • A ban on the provision, exportation, or re-exportation, directly or indirectly, of goods, services or technology in support of exploration or production for deepwater, Arctic offshore, or shale projects; and
  • The suspension of general licences issued by the Nuclear Regulatory Commission for the export of source material, special nuclear material, by-product material and deuterium to Russia.

Imports
  • A ban on the import or acquisition of the following goods and technology consigned from or originating in Russia (as well as related services):
    • Russian-origin fish; seafood; alcoholic beverages;
    • non-industrial diamonds; and
    • oil, gas, coal and related products.
Services
  • A ban on the provision of maritime insurance to ships carrying Russian crude oilor/ refined oil products to or between third countries, unless the oil/ refined oil product has been sold below a specific price cap;
  • A ban on Russian aircraft from US airspace and the supply of any US-origin or US-controlled items for use in servicing aircraft operated by certain airlines;
  • A ban on accountancy, corporate formation, management consultancy, and PR services ; and
  • A ban on US advertising and sales of equipment to Channel One, Russia-1 and NTV.
Donetsk and Luhansk
  • Sanctions on the parts of Donetsk and Luhansk occupied by Russia prohibiting new investment and the import or export of goods, services or technology.

Belarus:

  • Similar bans on exports, imports and investment as apply to Russia.

OUR TEAM
 
Fieldfisher's experienced multi-disciplinary sanctions and export control team includes lawyers who have negotiated and drafted EU and UN sanctions regimes in Government and regularly sanctions advice to businesses operating around the world in a wide variety of sectors. We work closely with US partners to provide coordinated, comprehensive and practical advice to help business understand and manage the impact of sanctions.  For more information please contact Andrew Hood (Partner, International Trade): Andrew.hood@fieldfisher.com +44(0)330 460 6568
 
* The contents of this notice do not constitute legal advice and are provided for general information purposes only.

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