Sanctions tracker – latest EU and UK sanctions imposed on Russia

In the latest of our regular sanctions updates, we summarise the latest EU and UK developments in response to the conflict in Ukraine. As ever, the position continues to change rapidly and we will continue to provide updates via this blog.

EU

New economic sanctions

On 2 March, the Council of the EU announced a further package of EU economic sanctions measures against Russia.

The first of these is a prohibition on the provision of SWIFT services to the following Russian banks: Bank Otkritie, Novikombank, Promsvyazbank, Rossiya Bank, Sovcombank, VEB and VTB, together with any majority owned Russian subsidiaries of those entities. This prohibition is contained in Council Regulation (EU) 2022/345 amending Regulation (EU) No 833/2014 (the "2014 Russia Regulation") and comes into force on 12 March 2022.

At the same time, Regulation 2022/345 introduced:

• a prohibition on the sale, supply, transfer or export of euro-denominated banknotes to Russia, to any natural or legal person, entity or body in Russia, or for use in Russia (subject to exemptions for personal use and diplomatic missions/consular posts/international organisations); and
• a prohibition on investing, participating or otherwise contributing to projects co-financed by the Russian Direct Investment Fund, although Member State competent authorities may license such activities where due under contracts concluded before 2 March 2022.

Broadcasting sanctions

Also on 2 March, the EU announced the urgent suspension of the broadcasting activities of Sputnik and RT/Russia Today (the "Annex XV Entities") in the EU or directed at the EU. This suspension is implemented by Council Regulation (EU) 2022/350 which adds the following to the 2014 Russia Regulation:

• a prohibition for operators to broadcast or enable, facilitate or otherwise contribute to broadcast any content by the Annex XV Entities; and
• suspension of any broadcasting licence or authorisation, transmission and distribution arrangement with the Annex XV Entities.

Belarus sanctions

Finally, the Council of the EU announced further sanctions on Belarus for its role in support of Russia, in the form of the additional of 22 high ranked members of Belarusian military personnel to the EU asset freeze list. A list of the individuals can be found in the Annex to Council Implementing Regulation (EU) 2022/353.

The Council also announced further trade restrictions on Belarus in relation to:

• the supply to Belarus of dual use goods and military goods (together with related technical assistance, brokering services, other related services, financing or financial assistance, including (re)insurance); and
• the import, purchase or transport from Belarus of:
  • goods used for the production or manufacturing of tobacco;
  • certain mineral products;
  • potash products;
  • wood products;
  • cement products;
  • iron and steel products;
  • rubber products; and
  • certain machinery; and
• the provision of technical assistance, brokering services, financing or financial assistance (including (re)insurance) relating to the above imports.

These restrictions are set out in Council Regulation (EU) 2022/355 which also contains various exemptions and licensing grounds, including in relation to the execution of pre-existing contracts.

In a statement on 3 March, President von der Leyen indicated that this may represent a pause in the EU's currently planned sanctions package, saying: "the three waves of sanctions that we have already introduced have a massive impact on the Russian economy and therefore on Putin's war efforts. And we will introduce additional measures, if the situation deteriorates on the ground". Companies should therefore continue to closely monitor the position but it may be that international partners wait to see the effect of the current sanctions before introducing new measures.

UK

New designations

On 3 March, the UK announced that two further individuals had been added to its asset freeze list: Igor Shuvalov (Chairman of VEB's Management Board) and businessman Alisher Usmanov.

"Oligarch Taskforce"

In its press release announcing the above designations, the Foreign Commonwealth & Development Office also said that the Foreign Secretary is also establishing an "Oligarch Taskforce" of ministers and officials from departments including the Home Office, Treasury, Department for Business Energy and Industrial Strategy, Department for Levelling Up, Housing and Communities, and the National Crime Agency. This group will "coordinate cross-government work to sanction oligarchs, helping build cases against the list of oligarchs it has identified as targets".

Insurance-related sanctions (not yet in force)

Also on 3 March, HM Treasury announced its intention to introduce further legislation restricting Russian aviation and space companies from access to the UK insurance sector, stating that further details of this legislation will be available "in due course".