Sanctions against Russia: recent developments – 02/24/2022


On 22 February 2022 Russian President Vladimir Putin signed laws ratifying agreements with the  Donetsk and Luhansk People’s Republics (DNR and LNR) recognizing them as independent  states.

Sanctions below were adopted before President Putin announced a “special military operation” in Ukraine on 24 February 2022.


  1. Sanctions targeting Russian banks and sovereign debt

On 22 February 2022 US President Joe Biden addressed the nation elaborating on sanctions that the US will be introducing against Russia. Further to this, the US Treasury imposed the following restrictive measures pursuant to Executive Order (E.O.) 14024¹:

  • Full blocking sanctions on VEB bank and the Promsvyazbank (PSB), 42 of their subsidiaries  (including JSC VEB Leasing, LLC VEB Ventures and VEB Capital), as well as five vessels owned  by the PSB subsidiary, namely:

– Baltic Leader (IMO: 9220639), a Russian-flagged roll-on roll-off cargo vessel with a gross registered tonnage of 8831;

– Linda (IMO: 9256858), a Russian-flagged crude oil tanker with a gross registered tonnage  of 61991;

– Pegas (IMO: 9256860), a Russian-flagged crude oil tanker with a gross registered tonnage  of 61991;

– Fesco Magadan (IMO: 9287699), a Russian-flagged container ship with a gross registered  tonnage of 7519; and

– Fesco Moneron (IMO: 9277412), a Russian-flagged container ship with a gross registered  tonnage of 7519.


  • Sanctions concerning Russian sovereign debt. This extends existing sovereign debt prohibitions to cover participation in the secondary market for bonds issued after 1 March  2022 by the Central Bank of the Russian Federation, the National Wealth Fund of the Russian  Federation (“fond natzyonalnogo blagosostoyanye” or “FNB”), or the Ministry of Finance of  the Russian Federation²;


  • Blocking sanctions on Russian elites, namely:

– Denis Aleksandrovich Bortnikov, son of Aleksandr Vasilievich Bortnikov (already sanctioned), Director of the Federal Security Service (FSB) of the Russian Federation and a  permanent member of the Security Council of the Russian Federation.

– Petr Mikhailovich Fradkov, the Chairman and CEO of Promsvyazbank (PSB).

– Vladimir Sergeevich Kiriyenko, son of Sergei Vladilenovich Kiriyenko (already sanctioned),  First Deputy Chief of Staff of the Presidential Office.

As a result of today’s blocking actions, all property and interests in property of persons mentioned above that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC. In addition, any entities that are owned, directly or  indirectly, individually or in the aggregate, 50 percent or more by one or more blocked persons  are also blocked.

President Biden also stated that the Nord Stream 2 project will not be moving forward³. He also  requested that his administration prepared sanctions targeting Nord Stream 2 AG and its  executives.

  1. Sanctions targeting DNR and LNR

On 21 February 2022 President Biden signed Executive Order (E.O.) imposing sanctions targeting the DNR and LNR.

The measures prohibit:

  • New investment in the DNR or LNR by a United States person, 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 United States person, wherever located, of any goods, services, or technology to the  DNR or LNR;
  • Any approval, financing, facilitation, or guarantee by a United States person, wherever located, of a transaction by a foreign person where the transaction by that foreign person  would be covered by these prohibitions if performed by a United States person or within the  United States.

The E.O. also provides authority to impose sanctions on persons determined:

  • To operate or have operated since the date of the E.O. in the DNR;
  • To be or have been since the date of the E.O. a leader, official, senior executive officer, or  member of the board of directors of an entity operating in the DNR or LNR;
  • To be owned or controlled by, or to have acted or purported to act for or on behalf of, directly or indirectly, any person whose property and interests in property are blocked  pursuant to this E.O.;
  • To have materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, any person whose property and  interests in property are blocked pursuant to this E.O.

Simultaneously the Department of Treasury issued six licenses, that, inter alia, allow telecommunications and internet services to remain operational, and mail services to continue  in DNR and LNR.


  1. Sanctions targeting Russian individuals and trade with DNR and LNR

On 23 February 2022, Council of the EU adopted a package of measures following Russia’s recognition of DNR and LNR, according to publication made on the Official Journal of the European Union Volume 65 dated 23 February 2022. Particularly, the Council adopted a number of regulations and decisions sanctioning the 351 members of the State Duma who voted in favour of Russia’s recognition of DNR and LNR.

The sanctions also target 27 individuals and entities determined to have been destabilising the  situation, waging disinformation campaigns, and providing financial support to the DNR and  LNR. Those entities include:

  • Bank Rossiya;
  • VEB.RF;
  • Internet Research Agency.

Restrictive measures include an asset freeze and a prohibition from making funds available to the listed individuals and entities. In addition, a travel ban applicable to the listed persons prevents these from entering or transiting through EU territory.

Additionally, sanctions provide for an import ban on goods from DNR and LNR, restrictions on trade and investments related to certain economic sectors, a prohibition to supply tourism services, and an export ban for certain goods and technologies.

Moreover, Council of the EU introduced a sectoral prohibition to finance the Russian Federation,  its government, and Central Bank.

  1. Sanctions targeting Nord Stream 2

On 22 February 2022 German Chancellor Olaf Scholz announced suspension of the Nord Stream 2 certification.

Particularly, the government was requested to withdraw a security-of-supply assessment granted under Angela Merkel’s tenure. This report is required to authorize the pipelin  between Russia and Germany. The Chancellor stated that he had commissioned a new assessment into Germany’s energy security.


The UK imposed blocking sanctions pursuant to the Russia (Sanctions) (EU Exit) Regulations 2019 (S.I. 2019/855) targeting Russian financial entities and individuals, according to the statement made by Prime Minister Boris Johnson and the Financial Sanctions Notice published on the official website of the UK Government.

The following banks are subject to sanctions:

  • Bank Rossiya,
  • Industrialny Sberegatelny (IS) Bank,
  • Genbank,
  • Promsvyazbank, and
  • Black Sea Bank for Reconstruction and Development.

The following individuals are subject to sanctions:

  • Gennady Timchenko,
  • Boris Rotenberg, and
  • Igor Rotenberg.

Any assets they hold in the UK will be frozen, the individuals concerned will be banned  from travelling to the UK, the UK individuals and entities will be prohibited from having any dealings with such entities and individuals.

This is the first tranche of sanctions, according to Boris Johnson. The UK are, however, prepared to deploy further sanctions alongside the United States and the European Union  if the situation escalates further.


  1. Australia

On 23 February 2022, Australian Prime Minister Scott Morrison announced sanctions against Russia.

According to Prime Minister, Australia would initially impose travel bans and targeted financial sanctions on eight members of the Security Council of the Russian Federation.

The sanctions will also include entities linked to Moscow, as well as Russian banks, transport, energy, telecommunications, oil, gas, and minerals.

Australia will also extend the sanctions currently imposed on Crimea to include DNR and LNR.

No official document has been made available yet.

  1. Japan

On 23 February 2022, Japanese Prime Minister Fumio Kishida announced sanctions against Russia.

Sanctions include prohibiting the issuance of Russian bonds in Japan and freezing the assets

of certain Russian individuals as well as restricting travel to Japan, according to Prime Minister.

No official document has been made available yet.

  1. Canada

On 22 February 2022, Canadian Prime Minister Justin Trudeau announced sanctions against Russia.

The first round of economic sanctions will ban Canadians from all financial dealings with the DNR and LNR. The sanctions will also target members of the Russian parliament who voted for the decision to recognize DNR and LNR, as well as ban Canadians from engaging in purchases of Russian sovereign debt.

No official document has been made available yet.


As of 22 February 2022, Russia has not introduced any new restrictive measures countering US,  EU, and UK sanctions, nor was there any movement on already introduced draft laws in this  regard. We are following all the developments of such legal initiatives in our monthly sanctions’  updates.

We are actively following the developments related to those issues  and are fully prepared to advise our clients.

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