Sanctions tracker – further UK and EU sanctions against Russia announced

This briefing summarises the latest UK and EU sanctions developments in response to the conflict in Ukraine.

UK

New designations

On 6 April, the UK's Office of Financial Sanctions Implementation ("OFSI") announced the addition of ten further entries to the UK's asset freeze list, comprising eight individuals (described as oligarchs active in key Russian strategic industries) and two banks (Sberbank and Credit Bank of Moscow).

New and amended general licences ("GLs")

On the same day, OFSI issued a new GL - GL INT/2022/1544176 – permitting the winding down of transactions involving Credit Bank of Moscow or any entities owned or controlled by it ("subsidiaries").  The GL expires on 6 May 2022.

OFSI also amended its existing Sberbank GL - GL INT/2022/1277877 - which was issued when Sberbank was designated for the purposes of restrictions on the provision of correspondent banking services and processing of sterling payments, as discussed in our previous blogpost. This has been amended to permit dealings with Sberbank's funds or the making available of funds to or for the benefit of Sberbank for the purposes of processing payments relating to the making available of crude oil, petroleum products and gas in the UK. This GL expires on 24 June 2022.

At the time of writing, no general 'wind down' licence relating to Sberbank had been issued. As such, the only transactions currently permitted under licence would be those related to energy (as described above), and any individually licensed transactions.

OFSI has also made amendments to two other GLs, as set out below:

• amendments to GL INT/2022/1280876 relating to VTB Capital plc on 1 April to permit payments in connection with insolvency proceedings relating to VTB Capital plc; and
• amendments to GL INT/2022/1438977 relating to GEFCO on 4 April to permit the processing of payments or transactions relating to the sale and transfer of Russian Railways' shares in GEFCO.

New sanctions announced (not yet in force)

On 6 April, the UK announced further planned sanctions against Russia, including:

• an "outright ban" on all new outward investment to Russia;
• proposals to end all dependency on Russian coal and oil and an end to imports of Russian gas "as soon as possible thereafter";
• a ban on the export of key oil refining equipment and catalysts (stated to come into effect next week (w/c 11 April)); and
• a ban on the import of Russian iron and steel products.

With the exception of the oil refining equipment restrictions mentioned above, the announcement does not specify when the various measures are intended to come into force. No new legislation had been published at the time of writing.

EU

New sanctions proposed (not yet in force)

On 5 April, President von der Leyen made a statement proposing a fifth round of EU sanctions against Russia. The package comprises six pillars, as set out below:

1. an import ban on Russian coal;
2. a "full transaction ban" on four Russian banks, including VTB;
3. a ban on Russian and Russian-operated vessels from accessing EU ports and on Russian and Belarussian road transport operators;
4. export bans in relation to quantum computers, advanced semiconductors, sensitive machinery and transportation equipment;
5. import bans on "products from wood to cement, from seafood to liquor"; and
6. a general ban on participation of Russian companies in Member State public procurement or exclusion of financial support to Russian public bodies.

The statement also notes that further designation of individuals is in progress, and that the EU is working on additional sanctions, including in relation to oil imports and "reflecting on" ideas presented by Member States "such as taxes or specific payment channels such as an escrow account".

At the time of writing, no legislation has been published  in relation to these new restrictions.

Additional EU FAQs

The Commission has continued to update its FAQs, including through the addition of new documents relating to circumvention and due diligence and crypto-assets.