Sanctions Tracker Summary – Global Sanctions Responses to the Crisis in Ukraine

Updates from February 4, 2022 through March 11, 2022.

Within a brief period, the international sanctions environment applicable to trade with Russia has been fundamentally transformed, such that Russia is, in many respects, now a comprehensively sanctioned jurisdiction.  We have published a number of recent updates regarding sanctions measures that have been proposed and enacted in several jurisdictions as a response to the conflict in Ukraine.  These updates are available on Sanctions Notes, which utilizes our deep network of sanctions experts to keep you at the forefront of major developments in sanctions measures, export control and trade regulations, and other compliance issues.

We invite you to subscribe to Sanctions Notes here.

Throughout the past few weeks, we have analyzed the following notable developments:

• Australia Updates. On February 25-27, 2022, Australia extended its Ukraine-related sanctions measures against additional individuals and entities under the Autonomous Sanctions Regulations 2011 (Cth).  Prime Minister Scott Morrison also foreshadowed in a press release that Australia will continue to coordinate its sanctions response with the US, UK, and EU to target key Russian banks, institutions, and individuals.  The full post is available here, here, here.
• Japan Updates. On March 1, 2022, Japan implemented sweeping Russia-related sanctions in addition to the ones previously in place from 2014 which concerned the annexation of Crimea.  Japan’s Prime Minister, Fumio Kishida, also announced that Japan would join the EU, US, and other countries in blocking certain Russian banks’ access to the SWIFT.  The full post is available here.
• EU/UK Updates. The EU and UK have announced numerous Ukraine-related sanctions in the past few weeks.  Notably, the UK passed several new pieces of sanctions legislation concerning sanctions applied to certain Russian banks, including SWIFT sanctions, as well as restrictions on transferable securities, lending, and correspondent banking, among others.  The EU also announced further restrictive measures concerning aviation and transactions involving the Russian Central Bank.  The full posts are available here, here, here, here, here, here, here, here, and here.
• US Updates. The US announced significant updates to its Ukraine-related sanctions measures in the past week.  These included the sanctions designations of numerous Russian banks and other entities and persons, suspension of Russian flights to and/or from the US; the announcement of a US Department of Justice task force dedicated to prosecuting violations of Russia-related sanctions; and President Biden’s recent Executive Order targeting the importation of Russian oil, liquefied natural gas, and coal to the United States.  The full posts are available here, here, here, here, here, here, and here.
• Russian Countersanctions. In response to sanctions imposed against it by various countries, Russia began implementing countersanctions in late February 2022 that, among other things, placed certain restrictions on Russian “currency control residents” and to prohibit divestment of foreign investors from Russian assets.  The full post is available here.

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We will continue to monitor developments in this area and encourage you to subscribe to be kept informed of latest developments.  Please contact the authors or your usual Herbert Smith Freehills contacts for more information.