Update on Russia Sanctions

Skadden Publication

Response to the Russian invasion of Ukraine has been swift and coordinated, with the U.S., U.K. and EU, among other allied nations, imposing a series of sanctions and export controls on key elements of the Russian economy.

These client alerts are for informational purposes only and do not constitute legal advice. Complex assessments often have to be made as to which sanctions regime applies in any given instance, given the multinational touch points of many entities and individuals. In that regard, given the complex and dynamic nature of these sanctions regimes, there may be developments not captured in these summaries. Moreover, while the summaries were accurate when written, they may become inaccurate over time given developments. For all of these reasons, you should consult with a qualified attorney before making any judgments relating to sanctions, as there are potentially severe consequences of failing to adhere fully to sanctions restrictions.

REPO for Ukrainians Act Provides for the ‘Repurposing’ of Seized Russian Sovereign Assets
May 2, 2024

The much-publicized legislation funding military aid for Ukraine, Israel and Taiwan also contained a provision authorizing the U.S. government to seize Russian sovereign assets that are currently frozen and “repurpose” them to support Ukraine.

New BIS Rule Imposes Stringent Export Control Restrictions Targeting Large Number of OFAC-Sanctioned Parties
March 25, 2024

On March 21, BIS published a final rule amending the EAR by imposing “end user” export control restrictions against individuals and entities designated under 11 sanctions programs administered by OFAC.

EU Expands Restrictive Measures in 13th Russian Sanctions Package and Publishes Guidance
March 11, 2024

The EU imposed asset freezes on more individuals and entities in its latest Russian sanctions package, and restricted exports to 27 companies deemed to be involved in circumventing sanctions. It also issued new guidance on sanctions.

UK Publishes First Sanctions Strategy and New Licensing Guidance
March 11, 2024

The UK has released its first sanctions strategy, explaining the government’s use of sanctions as a foreign policy and security tool and signaling future areas of focus. OFSI also announced the licensing principles for designated individuals.

UK Announces Creation of New Trade Sanctions Enforcement Agency and Introduces Further Sanctions Against Russia
January 22, 2024

The UK’s latest measures against Russia include import restrictions on certain Russian metals, ancillary services for luxury goods and Russian diamonds. The government has also announced the creation of an agency to enforce trade sanctions.

EU Further Strengthens Restrictive Measures Against Russia in 12th Package of Sanctions
January 9, 2024

The EU has adopted a 12th package of sanctions against Russia that, among other things, imposes an asset freeze on over 140 individuals and entities and expands existing sectoral sanctions targeting key aspects of the Russian economy.

UK Broadens Compliance Advice Exception Under Legal Services Ban
August 21, 2023

The UK government has issued a general licence in relation to the legal services ban that extends the sanctions compliance advice exception to include advice relating to sanctions imposed against Russia by any jurisdiction, not just the UK.

EU Increases Russia-Related Restrictions and Expands Anti-Circumvention Measures in 11th Package of Sanctions
July 10, 2023

The EU’s latest Russian sanctions package aims to limit circumvention by expanding restrictions and adding enforcement powers. The new rules also extend export restrictions on dual-use goods and technology, and impose new asset freezes.

In Coordinated Action, US Authorities Increase Russia-Related Restrictions and Warn About Evasion Risks
June 1, 2023

The U.S. has launched a coordinated effort to expand and strengthen enforcement of its sanctions campaign against Russia. Multiple government agencies appear to be increasingly shifting toward an enforcement posture.

EU Adopts 10th Set of Sanctions Against Russia and Strengthens Enforcement and Anti-Circumvention Measures 
March 23, 2023

The EU has sanctioned 121 new individuals and entities, expanded sectoral restrictions and imposed new reporting requirements. Stressing multilateral enforcement, it flagged common sanctions evasion methods that companies should watch for.

New US Efforts To Prosecute Sanctions Evasion and Export Control Violations May Require Compliance Programs To Be Updated
March 16, 2023

Companies should ensure that their compliance programs align with the latest guidance from the U.S. government, which has assigned new resources to prosecuting sanctions evasions and export control violations.

US Commerce Department Expands Export Restrictions Targeting Russia and Belarus
March 8, 2023

The latest expansion of U.S. sanctions against Russia and Belarus adds hundreds of product categories and scores of listed entities. New licensing requirements were also added to prevent Iran from supplying drones for use in Ukraine.

Latest EU Russian Sanctions Expand Sector Restrictions and Add Designated Individuals and Entities
December 22, 2022

New EU sanctions against Russia include a ban on mining investments and further export restrictions on dual-use items and technology. Business services and media bans were extended and additional individuals and entities have been sanctioned.

UK Expands Prohibitions on Providing Services to Russian Entities and Adds Investment Restrictions
December 22, 2022

The UK expanded restrictions on Russian investments, securities and loans, and enlarged its bans on the provision of professional and business services. Providing trust services to persons connected with Russia is also now prohibited.

EU and UK Price Cap on Russian Crude Oil
December 20, 2022

The EU and UK price cap on Russian crude oil and related rules governing its transportation and related services were accompanied by detailed guidance from both jurisdictions that will assist in compliance.

Price Cap on Russian Crude Oil Becomes Effective 
December 12, 2022

On December 5, 2022, a price cap went into effect, prohibiting the provision of certain services that enable maritime transportation of Russian crude oil unless the oil is purchased at or below the price cap.

Latest UK Sanctions Against Russia
December 5, 2022

In response to the continued invasion of Ukraine, the U.K. has added to its measures targeting Russia. The actions include additional designations to freeze assets, expanded trade sanctions and export controls, further prohibitions on certain loan and credit arrangements, and the publication of new and in some cases amended general licences.

US, UK and EU Expand and Amend Russian Sanctions, Responding to Purported Annexations of Ukrainian Regions
October 7, 2022

The U.S., U.K. and EU expanded sanctions and provided new guidance regarding sanctions and export controls in response to the referendums Russia sponsored in four Ukrainian regions and its purported annexation of those territories.

EU and UK Adopt Further Sanctions and Export Controls Targeting Russia
August 1, 2022

Recent updates extend EU and UK sanctions to oil products, gold, professional services, social media, internet services and apps, while adding designated entities and individuals, further restricting investments and bolstering enforcement powers.

UK’s Red Alert on Financial Sanctions Evasion Signals Regulatory Alignment on Future Sanctions Enforcement
August 1, 2022

The U.K. government has issued a report on the ways Russian elites are suspected of attempting to evade sanctions imposed as a result of the war in Ukraine. The report unequivocally signals regulators’ interest in purported enablers of sanctions evasion.

US Adopts Further Sanctions and Export Controls Targeting Russia
July 29, 2022

US Adopts Further Sanctions and Export Controls Targeting Russia In the last month, the U.S. strengthened and clarified its sanctions and export control framework targeting Russia: sanctioning new targets, issuing guidance on the ban on new investment in Russia, prohibiting the provision of certain professional services to Russia and further tightening controls on exports to Russia and Belarus.

The Future Landscape of the UK Sanctions Regime
July 11, 2022

Recent legislation and increased staffing may strengthen the UK’s post-Brexit sanctions regime, but as UK rules diverge from the EU’s, and with limited guidance from the government, companies face many unanswered compliance questions.

US, UK and EU Impose New Sanctions and Export Controls on Key Elements of Russian Economy
April 25, 2022

The U.S., U.K. and European Union, among other allied nations, have rolled out additional sanctions and export controls as the Russian invasion of Ukraine continues, including in response to possible war crimes in Ukraine.

UK and EU Impose Further Ukraine-Related Sanctions on Russia and Belarus
March 24, 2022

The latest round of UK and EU sanctions extend restrictions on imports, exports and financing, and subject Belarus and dozens of additional individuals and entities to the limitations.

New US Restrictions Impact Russia-Related Imports and Exports, US Dollar-Denominated Banknotes
March 17, 2022

On March 11, 2022, President Joe Biden signed an executive order imposing restrictions on imports and exports with respect to Russia as well as on the supply of U.S. dollar-denominated banknotes to the Russian government and to persons located in Russia.

US Bans Russian Oil Imports and Restricts Investment in Russia’s Energy Sector
March 11, 2022

On March 8, 2022, President Joe Biden banned the import of Russian oil, gas and other energy products into the U.S. and imposed sweeping prohibitions on new U.S. investment in the Russian energy sector, as well as on the facilitation of such transactions by foreign persons.

US, UK and EU Ramp Up Sanctions and Export Controls as Russia’s Invasion of Ukraine Continues
March 9, 2022

The U.S., U.K. and EU's additional sanctions and export controls on Russia have been closely coordinated in an effort to put further stress on the Russian financial and defense sectors, target certain Russian oligarchs and their families, restrict exports to Russia, ban overflights by Russian aircraft and further prevent Russia’s ability to use its foreign-held reserves to prop up the ruble and fund its war in Ukraine.

Russia Restricts Transactions With Nationals of Sanctioning Countries and Further Limits Transfers of Funds Abroad
March 2, 2022

On March 1, 2022, Russian President Vladimir Putin adopted additional economic measures in response to sanctions from the U.S. and Europe. The Bank of Russia also imposed restrictions on the transfer of funds outside of the country.

Russia Responds to US, UK and EU Sanctions With New Economic Measures
February 28, 2022

On February 28, 2022, Russian President Vladimir Putin ordered special economic measures that include the mandatory “sale” of foreign exchange proceeds, restrictions on cross-border currency operations, a continuation of the simplified process for certain companies to buy back shares and the ability for banks to open accounts for individuals remotely.

US, UK and EU Impose Significant Sanctions and Export Controls in Response to Russia’s Invasion of Ukraine
February 26, 2022

The U.S., U.K. and EU, among other allies, have moved rapidly with economic sanctions and export controls in response to Russia’s invasion of Ukraine. Government officials have indicated that the sanctions and export controls implemented or announced to date represent the early stages of the coordinated response. Further possible action means the legal landscape remains very fluid.