Sanctions against Russia, recent developments (updated 22 march)


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.

On 24 February 2022 President Putin announced a “special military operation” in Ukraine.

Sanctions were adopted against Russia further to these actions of Russia (please see our legal alerts on sanctions against Russia dated 24 and 28 February 2022, and 2 March).

This additional legal alert is mainly focused on the fourth round of sanctions adopted by the European Union (EU), the United States, and the UK.

Additionally, Switzerland announced that their blocking sanctions now fully correlate with the EU blocking list.


New block of coordinated sanctions introduced

On 11 March President Biden issued Executive Order imposing  restrictions on certain imports, exports and new investment. 1

The sanctions include:

►Ban on exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, of luxury goods, and any other items as may be determined by the Secretary of Commerce, in consultation with the Secretary of State and the Secretary of the Treasury, to any person located in the Russian Federation. Luxury goods have not been defined as of moment.

►Ban on importation of the following products of Russian Federation origin:  fish, seafood, and preparations thereof; alcoholic beverages; non-industrial diamonds; and any other products of Russian Federation origin as may be determined by the Secretary of the Treasury.

►Ban on exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, of U.S. dollar-denominated banknotes to the Government of the Russian Federation or any person located in the Russian Federation.

Additionally, on 11 March, the United States announced joint measures together with Canada, France, Germany, Italy, Japan, and the United Kingdom as well as the European Union, according to the White House official press-release. Such measures include:

►Revoking Russia’s most-favored nation status.

►Denying borrowing privileges at multilateral financial institutions, including the International Monetary Fund and the World Bank.

►Full blocking sanctions on additional Russian elites and their family members.

►New guidance by the Department of Treasury to evade sanctions evasion, including through virtual currency.

►Ban new investment in any sector of the Russian Federation economy by a United States person wherever located.


EU introduced fourth package of sanctions

On 15 March 2022, the EU decided to impose a fourth package of economic and individual sanctions in response to Russia’s supposed actions in Ukraine. 2 The new measures include a prohibition on:

►all transactions with certain state-owned enterprises including Rosneft, OBORONPROM, United Aircraft Corporation, Uralvagonzavod, Trasneft, Gazprom Neft, Almaz Antey, Kamaz, Rostec, Sevmash, Roscomflot, United Shipbuilding Corporation.

►the provision of credit rating services to any Russian person or entity. Credit rating is defined as an opinion regarding the creditworthiness of an entity, a debt or financial obligation, debt security, preferred share or other financial instrument, or of an issuer of such a debt or financial obligation, debt security, preferred share or other financial instrument, issued using an established and defined ranking system of rating categories.

►new investments in the Russian energy sector which is defined as:

+the exploration, production, distribution within Russia or mining of crude oil, natural gas or solid fossil fuels, the refining of fuels, the liquefaction of natural gas or regasification.

+the manufacture or distribution within Russia of solid fossil fuel products, refined petroleum products or gas; or

+the construction of facilities or installation of equipment for, or the provision of services, equipment or technology for, activities related to power generation or electricity production.

The Council expanded the list of persons connected to Russia’s defense and industrial base, on whom tighter export restrictions were imposed regarding dual-use goods, and goods and technology which might contribute to Russia’s technological enhancement of its defense and security sector. The EU also introduced:

►trade restrictions for iron and steel. It becomes prohibited to import iron and steel originated in or exported from Russia; to purchase iron and steel that originated from Russia; or provide any assistance related to these prohibitions.

►trade restrictions on luxury goods to Russian persons or for use in Russia. Banned goods are listed in an annex and generally refer to items exceeding EUR 300 per item.

►sanctions on an additional 15 individuals (including Roman Abramovich, German Khan, Alexander Shokhin, Konstantin Ernst, Tigran Khudaverdyan) and 9 entities (particularly, Russian Helicopters, United Shipbuilding Corporation, Rosneft Aero, JSC Rosoboronexport, High Precision Systems).

On 16 March 2022 Switzerland announced that its list of sanctioned individuals and entities now fully mirrors that of the EU.


UK introduced a fourth block of sanctions

On 15 March UK announced its fourth package of sanctions targeting Russia. 3 The new sanctions target Russian individuals and entities. Those subject to the sanctions will have their assets in the UK frozen, be banned from travelling to the UK and no UK citizen or company may do business with them.


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