Following the invasion of Ukraine by Russia, the European Union (EU) has issued significant and far-reaching sanctions and restrictive measures on Russia and the Russian economy in tandem generally with the governments of the United States of America, Canada and the United Kingdom.

Note: The position is constantly evolving and we will continue to update the instruments published on this blog. This blog follows on from our previous EU-Russia sanctions blog posts which can be found here and here. Please find an updated table of sanctions here.

Summary of new measures

The sanctions have been implemented in tranches over the last few days as the severity of the crisis has escalated.

On 23 February, a first package of sanctions against Russia was adopted to respond to the decision by Russia to proceed with the recognition of the non-government controlled areas of Donetsk and Luhansk oblasts in Ukraine as independent entities, and the ensuing decision to send Russian troops into these areas. The sanction in this tranche include the following:

• Targeted sanctions against the 351 members of the Russian State Duma and an additional 27 individuals.
• Restrictions on economic relations with the non-government controlled areas of Donetsk and Luhansk oblasts – in effect, an embargo on these regions which are similar to those on Crimea and Sevastopol.
• Restrictions on Russia's access the EU’s capital and financial markets and services.

On 24 and 25 February, a second tranche was implemented immediately following the invasion of Ukraine. These sanctions target the financial sector, the energy and transport sectors, dual-use goods, export control and export financing, visa policy, additional sanctions against Russian individuals and new listing criteria. These were implemented in general through enhancements to the EU’s cornerstone Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine.

The restrictions and prohibitions specifically cover:

• Exports of dual-use goods and technology and on the provision of related services, as well as restrictions on exports of certain goods and technology which might contribute to Russia’s technological enhancement of its defence and security sector.
• The provision of public financing or financial assistance for trade with, or investment in, Russia, subject to certain exceptions.
• The sale, supply, transfer or export to Russia of specific goods and technologies for use in oil refining, together with restrictions on the provision of related services.
• Export ban covering goods and technology suited for use in aviation and the space industry and prohibits the provision of insurance and reinsurance and maintenance services in relation to those goods and technology.
• Expanding the existing financial restrictions, in particular those on access by certain Russian entities to the capital markets –
  • including elimination of maturity periods for debt issued after 12 April 2022 (article 5);
  • addition of new Annex XII (now includes Alfa Bank and Otkritie Bank).
• The listing and provision of services in relation to shares of Russian state-owned entities on Union trading venues.
• Restrictions on the acceptance of deposits exceeding certain values from Russian nationals or residents, the holding of accounts of Russian clients by EU based central securities depositories as well as the sale of euro-denominated securities to Russian clients.
• Bank account reporting requirements where EU bank accounts hold in excess of €100,000 for Russian clients.

On 25 February, the EU also imposed sanctions against Vladimir Putin and Sergey Lavrov alongside members of the National Security Council of the Russian Federation and on the remaining members of the Russian State Duma who supported Russia’s immediate recognition of the self-proclaimed Donetsk and Luhansk “republics”.

On 28 February, the most recent tranche of sanctions was launched including:

• a ban on transactions with the Russian Central Bank
• €500 million support package to finance equipment and supplies to the Ukrainian armed forces
• a ban on the overflight of EU airspace and on access to EU airports by Russian carriers
• new sanctions on additional 26 persons and one entity, including numerous ultra-high net worth Russian businessmen (oligarchs) such as Igor Sechin, chief executive of Rosneft Oil Co.; Alexey Mordashov, the majority owner of steel giant Severstal PAO; Alisher Usmanov; and Mikhail Fridman and Petr Aven, founders of Alfa Bank.

Consolidated table of EU sanction measures on Russia

These measures referred to above were introduced through amendments to:

• Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine;
• Decision 2014/145/CFSP concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine;
• Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine; and
• Decision 2014/512/CFSP concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine.

Click here to view the table.

Key takeaway

It is incredibly important that stakeholders reconsider their position in light of the multiple new sanctions measures introduced and take expert advice where appropriate. We are happy to assist on all EU and British Overseas Territories sanctions queries relevant to the jurisdictions we advise on.