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April 29, 2022

Two Months On: EU & U.K. Continue Expanding Russia Sanctions

Two months into Russia’s invasion of Ukraine, the EU and the U.K. have continued to expand their Russia sanctions programs. Here we summarise the measures introduced since our previous update and we overview where the EU and U.K. programs are since the invasion started on 24 February.

EU Announcements Since 6 April

  • 21 April: Asset freezes against Serhiy Vitaliyovich Kurchenko and Yevgeniy Viktorovich Prigozhin
  • 13 April: Humanitarian exemptions made to certain existing asset freezes and trade restrictions
  • 11 April: Twenty Russian airlines made subject to operating bans or restrictions on safety grounds
  • 8 April: Asset freezes against 217 individuals and 18 entities, including all 179 members of the so-called governments and parliaments of Donetsk and Luhansk, oligarchs and business people and family members, and the following financial, military, industrial and transportation entities:
    • JSC Arzamas Machine-Building Plant
    • JSC Ruselectronics
    • JSC Tacitical Missiles Corporation
    • JSC Kalashnikov Concern
    • JSC UEC Klimov
    • LLC Military Industrial Company
    • PO More Shipyard
    • JSC Omsk Transport Machine Factory Omsktransmash
    • JSC Russian Machines
    • JSC Sozvezdie Concern
    • JSC Research and Industrial Concern “Machine Engineering Technologies” — JSC RIC TECMASH
    • PJSC United Engine Corporation
    • Yantar Shipyard
    • Otkritie FC Bank
    • Novikombank
    • Sovcombank
    • VTB Bank
    • JSC GTLK

U.K. Announcements Since 6 April 

  • 21 April: Asset freezes against 16 individuals and the following 10 entities:
    • Aleksandrov Scientific Research Technological Institute NITI
    • Central Research Institute of Machine Building JSC
    • Federal Sate Unitary Enterprise Dukhov Automatics Research Institute
    • JSC Arzamas Machine-Building Plant
    • JSC GTLK
    • JSC Kalashnikov Concern
    • LLC Military Industrial Company
    • Promtech-Dubna JSC
    • Radiotechnical and Information Systems Concern
    • Rocket and Space Centre Progress JSC
  • 21 April: General licence granted allowing payments to Gazprombank under existing gas contracts until 31 May 2022
  • 14 April: The Russia (Sanctions) (EU Exit) (Amendment) (No 8) Regulations 2022 introduced:
    • Export prohibitions on luxury goods to Russia or persons connected with Russia
    • Prohibitions on imports/acquisitions of iron and steel products from Russia and supply of such products to third countries
    • Prohibitions on export of oil refining and quantum computing goods or technology to Russia or persons connected with Russia
  • 14 April: The Russia (Sanctions) (Overseas Territories) (Amendment) Order 2022 extended the U.K. Russia sanctions to British overseas territories
  • 14 April: Asset freezes against Eugene Tenenbaum and David Davidovich (associates of Roman Abramovich)
  • 13 April: Asset freezes against 206 individuals involved in destabilising Ukraine, undermining its territorial integrity or supporting the government of Russia
  • 8 April: Asset freezes against Katerina Vladimirovna Tikhonova and Maria Vladimirovna Vorontsova (daughters of Vladimir Putin) and Yekaterina Sergeyevna Vinokurova (daughter of Sergei Lavrov)
  • 6 April: Asset freezes against eight individuals and two entities involved in destabilising Ukraine, undermining its territorial integrity or supporting the government of Russia:
    • Viatcheslav (Moshe) Kantor
    • Andrey Guryev
    • Sergey Kogogin
    • Sergei Sergeivich Ivanov
    • Leonid Mikhelson
    • Andrey Akimov
    • Alexander Dyukov
    • Boris Borisovich Rotenberg
    • Credit Bank of Moscow
    • PJSC Sberbank
  • 6 April: General licence granted allowing the winding down of transactions involving Credit Bank of Moscow until 6 May 2022; Sberbank added to the existing general licence allowing energy-related payments
Overview of EU and U.K. Russia Sanctions Measures
Asset freezes and travel restrictions for designated individuals and entities 
Financial Restricted access to primary and secondary capital markets for certain Russian banks and companies
Prohibition on transactions with the Russian Central Bank and the Central Bank of Belarus
SWIFT ban for certain Russian and Belarusian banks
  Prohibition on the provision of euro-denominated banknotes to Russia and Belarus
  Prohibition on public financing or investment in Russia
  Prohibition on investment in and contribution to projects co-financed by the Russian Direct Investment Fund
Energy Prohibition on coal imports from Russia
  Prohibition of exports of oil refining goods and technology to Russia
  Prohibition on new investments in Russian energy sector
Transport Closure of airspace to Russian-owned and Russian-registered aircraft
  Closure of ports to Russian vessels
  Prohibition on Russian and Belarusian road transport operators
  Prohibition on exports to Russia of aviation, maritime and space industry goods and technology
Defence Prohibition on exports to Russia of dual-use goods and technology items that could contribute to defence and security capabilities
  Prohibition on trade in arms
Raw Materials and Other Goods
Prohibition on imports from Russia of iron, steel, wood, cement, seafood and liquor
Luxury Goods
Prohibition on exports of luxury goods
Media Prohibition on broadcasts by Russian state-owned media
Crimea and Sevastopol, Donetsk and Luhansk Import ban on goods
  Restrictions on trade and investment
  Export ban on certain goods and technologies

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