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

Updates from March 19, 2022 through April 12, 2022

Within a brief period, the international sanctions environment applicable to trade with Russia has been fundamentally transformed.  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 crisis 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.

In the past several weeks, we have analyzed the following notable developments:

• Australia Updates. On March 19, 2022, Australia designated aluminum ores (including bauxite), alumina and related products as “export sanctioned goods” for Russia on the basis that these goods are “key components in the manufacture and development of weapons.”  More recently, Australia announced its first set of financial and travel sanctions under the Magnitsky-style regulations, which were introduced to facilitate targeted sanctions against individuals responsible for, or complicit in, serious corruption, human rights violations and cyber-crime.  The new sanctions targeted Russian individuals responsible for corruption and human rights abuses relating to Sergei Magnitsky.  The full posts are available here and here.
• EU/UK Updates. Among several new Ukraine-related sanctions announced in the past few weeks, the UK’s Office of Financial Sanctions and Implementation provided an important update to its general guidance to include advice in respect of the aggregation of interests held by designated persons.  On March 30, 2022, the UK also published the Russia (Sanctions) (EU Exit) (Amendment) (No. 7) Regulations 2022, that amended the UK’s principal Russia sanctions legislation.  And last week, the EU announced the adoption of its fifth Russia sanctions package, which comprised, among many other things, a prohibition on the purchase, import or transfer into the EU of coal and other solid fossil fuels from Russia.  The full posts are available here, here, and here.
• US Updates. The US announced several updates to its Ukraine-related sanctions measures.  On April 6, 2022, President Biden issued an executive order broadly prohibiting all “new investments” in Russia by US persons.  The US Department of the Treasury’s Office of Foreign Assets Control also issued new sanctions designations against Sberbank, Alfa-Bank, and Alrosa, among many other individuals and entities.  The full posts are available here, here, and here.

Finally, in the fourth episode of our podcast, “Designated: A Sanctions Podcast,” we discussed the recent sanctions measures implemented in the US, UK, and EU as a response to the crisis in Ukraine, focusing on the Russian energy sector.  The podcast episode can be found 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.