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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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 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.
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.
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.
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.
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.
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.
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.
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.