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Volume XII, Number 229


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August 15, 2022

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EU Actions to Date on Russia and Russia-related Sanctions

The EU has responded to the conflict in Ukraine with the following sanctions measures (listed by date, beginning with most recent):

March 15, 2022: Council endorsed a fourth package of sanctions against Russia. Sanctions included a prohibition on transactions with certain state-owned enterprises and expands the list of persons connected to Russia’s defense and industrial base, on whom tighter export restrictions are imposed regarding dual-use goods and goods and technology, which might contribute to Russia’s technological enhancement of its defense and security sector.

Furthermore, restrictions were imposed on new investment across the Russian energy sector, as well as a comprehensive export restriction on equipment, technology and services for the energy industry in Russia, with the exception of the nuclear industry and the downstream sector of energy transport.

Sanctions were also imposed (applicable as of April 15, 2022) on the rating of Russia and Russian companies by EU credit rating agencies and the provision of rating services to Russian clients, resulting in a further loss of access to the EU’s financial markets.  The Council also introduced further trade restrictions concerning iron and steel, as well as luxury goods, introducing the prohibition to sell, supply, transfer, or export directly or indirectly, these goods.

Council also endorsed a new package of sanctions where key oligarchs (including Roman Abramovich and German Khan) and prominent business people in the iron and steel, energy, banking, media, military, and dual-use products and services are added in the sanctions list with their assets being frozen and a travel ban imposed. Sanctions are also imposed to lobbyists and propagandists, and to companies in the aviation, military/dual-use, shipbuilding, and machine-building sectors.

March 11, 2022: European Heads of State and Government announced following a meeting on March 10 in Versailles reiterating their support for Ukraine and confirming their willingness to issue further sanctions targeting Russia and Belarus. Additionally, the statement called for funds to be made available “without delay” through the adoption of the proposal on Cohesion’s Action for Refugees in Europe (CARE) and through ReactEU.

The statement also indicated support for Ukraine’s joining the EU, noting the Council has also invited the European Commission to submit its opinions on the applications of the Republic of Moldova and Georgia as well.

Group of Seven (G7) Leaders issued a statement reaffirming their commitment to sanctions on Russia as well as confirming efforts to reduce energy dependency on Russia through means, “[i]n addition to announced plans.” Further, the statement indicated the G7 will work through their national processes to deny Russia Most-Favored-Nation status on certain products. Additionally, the statement noted efforts to prevent Russia from obtaining financing from multilateral financial institutions, including the International Monetary Fund, the World Bank, and the European Bank for Reconstruction and Development.

March 9, 2022: Council endorsed the decision to ban three Belarusian banks from SWIFT and the prohibition of (i) transactions with the Belarusian Central Bank, (ii) listing of Belarus state-owned entities on EU trading venues from April 12, 2022, (iii)  acceptance of deposits exceeding €100,000 from Belarusian nationals or residents, and (iv) provision of euro banknotes to Belarus.

Additionally, the Council introduced additional restrictive measures with regard to the export of maritime navigation goods and radio communication technology to Russia. By virtue of this decision, it will be prohibited to sell, supply, transfer or export, directly or indirectly, maritime navigation goods and technology to any natural or legal person, entity or body in Russia, for use in Russia, or for the placing on board of a Russian-flagged vessel.

The Council also expanded the list of legal persons, entities and bodies subject to the prohibitions related to investment services, transferable securities, money market instruments, and loans.

Finally, the Council clarified the term “transferable securities” so as to clearly include crypto-assets, and thus ensure the proper implementation of the sectoral restrictions in place.

The Council endorsed a decision to add 14 oligarchs and business people as well as 146 members of the Russian Federation Council to the EU sanctions list.

March 2, 2022: The Council endorsed decision to ban certain Russian banks from SWIFT, prohibited the participation to projects financed by the Russian Direct Investment Fund, prohibited the sell, supply, transfer or export of euro banknotes to Russia.

Additionally, the Council suspended broadcasting activities of Sputnik and RT/Russia Today in the EU.

Council further endorsed sanctions against 22 high ranking members of the Belarusian military personnel (asset freeze and travel ban) and imposed export controls on dual-use goods and technology products, particularly these used for military and defense purposes.

February 28, 2022: The Council of the EU (the Council) endorsed the decision for the shutting down of EU airspace for all Russian-owned, registered, or controlled aircraft. Transactions with the Russian Central Bank have been prohibited.

Additionally, the Council endorsed 26 additional individuals added and 1 additional entity with asset freeze and travel ban within the EU sanctions package.

February 27, 2022: European Commission President Ursula von der Leyen announced shutting down EU airspace for all Russian-owned, registered or controlled aircraft. Banning of the state-owned RT/Russia Today and Sputnik, as well as their subsidiaries was also decided.

February 26, 2022: The European Commission, France, Germany, Italy, the UK, Canada, and the US issued a Joint Announcement on the imposition of further targeted sanctions against Russia, namely through removing Russian banks from the SWIFT banking system and imposing restrictive measures on the Russian Central Bank. Further coordination through a transatlantic task force has been agreed.

February 25, 2022: EU Foreign Ministers endorsed sanctions targeted at the financial, energy and transport sectors, dual-use goods, export control and export financing and visa policy. Export bans on oil refining technologies, aircraft, spare parts and equipment to Russian airlines as well as sensitive technologies have been included in the package of sanctions. Russian President Putin and Foreign Minister Lavrov were also the target of sanctions, with an asset freeze and travel ban in the EU.

February 24, 2022: EU heads of state of government agreed on a set of sanctions

February 23, 2022: Existing EU sanctions were extended to 351 members of the Russian Duma, 27 high profile individuals and 52 entities. Sanctions include asset freeze, restricted access to financial markets and export bans on an array of products including aluminum.

Our related publications: 

Additional US, UK and EU Sanctions on Russia (March 2022)

The US, UK, and EU Impose a Series of New Targeted and Territorial Russia-Related Sanctions(February 2022)

Russia Sanctions Update: What Risk Management Steps Can Be Taken Now? (February 2022)

Transatlantic Trade | US and Europe


© Copyright 2022 Squire Patton Boggs (US) LLPNational Law Review, Volume XII, Number 81

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