Articles Posted in EU Sanctions

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On 24 June 2024, the EU adopted its 14th package of sanctions against Russia.  The latest measures include:

  • The designation of 116 additional individuals and entities across a number of industries for their responsibility in undermining Ukraine’s territorial integrity, sovereignty, and independence.
  • A limited ban on contracts with Russian state energy companies and additional support for countries with energy needs to curb reliance on Russia.
  • Anti-circumvention measures, including requirements for EU parent companies to use “best efforts” to ensure that non-EU subsidiaries do not undermine EU sanctions.
  • A ban on the use of “System for Transfer of Financial Messages” (SPFS) (a Russian equivalent of SWIFT) by EU entities operating outside of Russia and a new power for the EU to designate third-country users of SPFS outside of Russia, which will then be subject to a transaction ban.
  • Comprehensive bans on port access by vessels contributing to Russian warfare, non-scheduled flights by controlled by Russian entities, and road transport of goods with 25% or more Russian ownership.
  • An amendment to the existing import-related restrictions concerning Russian diamonds.
  • Further import and export controls impacting Russia’s military-industrial complex and cultural property goods from Ukraine.
  • A requirement for the rejection of intellectual property rights applied for by Russian residents, nationals or entities.
  • A prohibition on accepting funding from the Russian state and its proxies by EU political parties, foundations, NGOs and media service providers.
  • An exemption to the ban on providing software services to Russia in cases where entities are controlled by an EU parent company and other select regions or services are provided by employees who were hired prior to February 2022.
  • A requirement for enhanced reporting, confidentiality requirements, and the promotion of voluntary self-disclosures.
  • Measures to allow EU operators to claim compensation in EU commercial and civil courts for damages caused by Russian companies further to sanctions.

These measures are summarized in further detail below.

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The United Kingdom introduced new sanctions against Russia on December 14, 2023, with the European Union also adopting its twelfth package of sanctions against Russia on December 18, 2023.

The latest UK restrictions include:

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The EU’s new Joint Communication on a European Economic Security Strategy proposes a methodology for an EU economic security risk assessment and identifies measures to mitigate these risks. The Strategy is noteworthy because it offers a comprehensive view of the EU’s overarching strategy for multiple existing or proposed new EU legislative and policy tools including export controls, FDI screening and domestic investment in critical technology through the EU’s own proposed Chips Act, and how these tools would work together to reduce EU economic security risks. It also signals the EU’s intention to align more closely with the U.S. regarding China, including with respect to reducing supply chain dependencies and new tools like outbound investment controls.

(This is the second post of a three-part series on U.S., UK and EU alignment on economic security strategy.)

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On February 24 and 25, 2023, the United Kingdom and European Union each adopted additional sanctions against Russia due to the ongoing conflict in Ukraine. These new measures are summarized below.

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In the final few days of September, the U.S. and global allies issued a number of sanctions and export controls against actors who have supported Russia’s referendums in Ukraine and related attempts to annex four Ukrainian territories. The referendums have been condemned by the Group of 7 (G7) nations, which committed to imposing further economic costs on individuals and entities both inside and outside of Russia.

The latest measures include actions by the Office of Treasury’s Office of Foreign Assets Control (OFAC), the U.S. Department of Commerce’s Bureau of Industry and Security (BIS), the U.S. Department of State, and the United Kingdom (UK) Office of Financial Sanctions Implementation (OFSI), as well as further announcements from the European Union (EU), described in turn below.

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UK DEVELOPMENTS

Further designations
On 10 March 2022, the UK Government added a further seven oligarchs to its list of sanctions targets, including the owner of Chelsea football club, Roman Abramovich. This was closely followed on 11 March 2022 by the sanctioning of 386 members of the Russian Duma (comparable sanctions had already been imposed by the EU).

Further aircraft-related sanctions
Airport operators, air traffic controllers and the Secretary of State have been granted new powers to issue directions to Russian aircraft (e.g., to take off, not to take off, and to land) and to suspend and revoke permissions needed to operate. The new provisions also allow the detention and movement of Russian aircraft and prohibit a person from providing aircraft insurance or reinsurance services to a person connected with Russia or where the aircraft is for use in Russia.

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The EU and UK have imposed additional export controls and sanctions with respect to Russia and Belarus connected to the Russian invasion of Ukraine. Below is a summary of key developments over recent days since our last blog post on EU and UK developments [here]. This is a rapidly developing area and future blog posts will summarize further developments.

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As the Russian invasion of Ukraine continues, the global pressure on the Putin regime intensifies with the EU issuing additional sanctions and export controls on Friday evening (February 25). The legislation implementing the UK’s latest announced sanctions is expected early this week. Both the EU and the UK have added further persons to their respective asset freeze lists, and both have now designated Mr. Putin and his Foreign Minister, Mr. Lavrov.

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The EU and UK have imposed further sanctions in response to the invasion of Ukraine and the recognition by Russia of the Donetsk and Luhansk People’s Republics (DNR and LNR) of Ukraine as independent territories.

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