Articles Tagged with russia 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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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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This post marks the second entry in our Year-in-Review series. For prior posts, click here.

Few sectors have been more affected by the sanctions on Russia than the energy industry. As Russia’s largest industry, it has been a focus of sanctions designed to deter the continuation and escalation of the conflict in Ukraine, with policies targeting the trade in oil and gas, new equity and debt, investment in energy projects, and export to Russia of equipment and parts, as well as designations of specific companies and individuals in the sector.

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On February 24, 2022, the United States (U.S.), European Union (EU), United Kingdom (UK), and other countries issued a barrage of sanctions against the Russian financial sector, cutting off many major banks from the global financial system. These initial measures were coordinated among the US, EU, UK and other G7 countries and largely mirrored one another. As the year progressed, the U.S., EU and UK each imposed new and distinct measures to restrict Russia’s ability to raise capital. Over time, important deviations between jurisdictions began to emerge, creating a vast and multijurisdictional impact on Russia’s financial sector. Russia, in turn, imposed its own measures in an attempt to mitigate that impact. In order for companies to operate in global markets, it became increasingly necessary to understand how to navigate multiple sanctions regimes. Below, we describe several of the key measures levied against the Russian financial sector over the past year.

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In response to Russia/Ukraine conflict, and Belarus’ ensuing support for Russia, the United States and global allies have imposed sweeping sanctions and export control restrictions on both Russia and Belarus. These actions are discussed extensively in our prior publications.

The sanctions and export controls restrictions especially target Russia and have had a significant impact on the Russian economy. Virtually every industry is impacted, and Russia’s financial institutions, businesses and prominent individuals are being targeted by ever-widening sanctions and export control restrictions imposed by the United States and global allies. As the situation evolves, further restrictions remain possible.

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On February 27, 2022, the U.S., UK and EU announced their agreement that certain Russian banks would be delisted from the Belgian-based Society for Worldwide Interbank Financial Telecommunication (SWIFT). The EU, which has jurisdiction over SWIFT, implemented sanctions measures that will ban the organization, effective March 12, 2022, from providing financial messaging support anywhere in the world for the following Russian financial institutions and their Russian subsidiaries:

  • Bank Otkritie;
  • Novikombank;
  • Promsvyazbank (PSB);
  • Bank Rossiya;
  • Sovcombank;
  • Vnesheconombank (VEB); and
  • VTB Bank

The SWIFT announcement has raised questions about how this action relates to existing sanctions and general licenses for Russian banks. We explore the differences below.

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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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On February 24, 2022, the U.S. Government issued a number of sanctions measures in response to Russia’s attack on Ukraine. These measures include sweeping financial sanctions and stringent export controls, which will have broad impacts on companies and individuals doing business in Russia, Ukraine and Belarus. Today’s announcement came alongside additional measures coordinated with U.S. allies, including the United Kingdom, European Union, Canada and Japan.

A brief overview of today’s U.S. measures is provided below. In following blogs, we will provide more focused looks at (a) U.S. sanctions; and (b) sanctions and export controls issued by a number of other key economies around the world.

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On February 22 and 23, 2022, President Biden announced further sanctions in response to Russia’s invasion of Ukraine. These sanctions build upon the U.S. sanctions issued on February 21, 2022. Specifically, the additional sanctions include (a) blocking two Russian financial institutions and their subsidiaries, as well as five Russian individuals associated with the Putin regime; (b) expanded sanctions targeting Russian sovereign debt and persons who support such transactions; and (c) sanctions on Nord Stream AG and its CEO.

The United Kingdom, European Union, Canada, Australia, and Japan have also issued or announced sanctions in response to Russia’s invasion.  Further sanctions are likely if the situation in Ukraine continues to escalate.

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In response to President Putin’s televised recognition of Donetsk and Luhansk People’s Republics (“DNR” and “LNR”) of Ukraine as “independent” nations, and reports of Russian troops being ordered into Ukrainian territory, the United States has imposed Crimea-style comprehensive sanctions on the DNR and LNR prohibiting new U.S. investment as well as imports and exports to and from the regions. The EU and the UK have sanctioned banks and oligarchs, and Germany has suspended certifications on the NordStream2 pipeline project.

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