EU Announces Fifth Round of Russian Sanctions; U.K. Extends Financial Sanctions

On April 5, 2022, the EU announced the fifth package of sanctions against Russia. The latest round, aimed at cutting deeper into the Russian economy, will focus on the following six areas:

1. An import ban on coal from Russia, which is estimated to cost Russia EUR 4 billion a year.
2. A full transaction ban on four key Russian banks, among them VTB, the second largest Russian bank. The four banks now totally cut off from the EU financial markets represent 23% of the Russian banking sector.
3. Subject to certain exceptions concerning essential products, such as food and agricultural products, humanitarian aid and energy products, a ban on Russian vessels and Russian-operated vessels from accessing EU ports. This ban is designed to limit options for Russia to obtain key goods.
4. Additional targeted export bans, worth EUR 10 billion, in areas in which Russia is vulnerable. This ban will include, for example, quantum computers and advanced semiconductors, as well as sensitive machinery and transportation equipment.
5. New import bans, worth EUR 5.5 billion, to cut the money stream to Russia and its oligarchs, on products from wood to cement, from seafood to liquor. This will also close the loophole between the current Russian and Belarussian sanctions.
6. A general ban on Russian companies participating in EU public procurement processes, as well as excluding all EU financial support to Russian public bodies. The purpose of this is to preclude any EU tax money from going to any Russian companies.

New U.K. Regulations & Sanctions

In addition to the EU’s sanctions, the U.K. continues to expand its sanctions regime in response to Russia’s invasion of Ukraine. On March 30, 2022, new regulations came into effect targeting Russian oligarchs’ aircraft and ships to prohibit access to aviation and shipping technical assistance. These regulations further introduce a power to designate individuals or entities by description under the standard or urgent procedure introduced by the Economic Crime Act 2022 and correct some errors and resolve issues arising from previous amendments to the Russia sanctions regulations.

This new legislation also extends existing finance, shipping and trade sanctions relating to Crimea to the areas of the Donetsk and Luhansk oblasts not under Ukrainian government control.

Expansion of U.K. Asset Freezes & Travel Bans

The U.K. has added the following individuals and entities to its U.K. Sanctions List and its Consolidated List making them subject to asset freezes and travel bans.

Individuals:

• Mikhail Yevgenyevich Mizintsev, Chief of the National Defence Command and Control Centre and in command of the siege of Mariupol
• Anton Sergeevich Anisimov, editor-in-chief of Sputnik news organisation.
• Andrej Grigoryevich Areshev, subject to sanctions by Australia
• Anton Sergeyevich Bespalov, subject to sanctions by Australia
• Sergey Borisovich Brilev, anchor and deputy director of Rossiya Television and Radio Other Information
• Irina Sergeyevna Bubnova, subject to sanctions by Australia
• Vladimir Ilich Maksimenko, subject to sanctions by Australia
• Alexey Lvovich Nikolov, managing director of Russian broadcaster RT (formerly Russia Today)
• Sergei Ivanovich Saenko, subject to sanctions by Australia
• Natalya Petrovna Skorokhodova, subject to sanctions by Australia
• Svetlana Georgiyevna Zamlelova, subject to sanctions by Australia
• Aleksandr Alexandrovich Aleksandrovich, CEO of Gasprom-Media Holding

Organizations:

• Wagner Group
• Rossiya Segodnya, a major Russian media organisation
• TV-Novosti, a major Russian media organisation
• Photon Pro LLP
• Majory LLP
• Djeco Group LLP

Photon Pro LLP, Majory LLP and Djeco Group LLP were also designated by OFAC for their alleged connections to a “sanctions evasion network.”

Since February 24, 2002, the U.K. has sanctioned banks with £500 billion of global asset value and more than £150 billion of net worth from oligarchs and their family members.

U.K. General Licenses

The U.K. has issued or amended the following general licenses:

• a general license allowing the winding down period until May 15, 2022 to allow closing out of trading positions with Sovcomflot or its subsidiaries.
• a general license concerning “Payments by the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation related to debt issued by them before 1 March 2022”, which authorizes until June 30, 2022 the provision of financial services for the purposes of the receipt and onward transfer of non-rouble denominated interest/coupon or maturity/principal payments from the Central Bank of Russia, the Russian National Wealth Fund or the Russian Ministry of Finance, or persons owned/controlled or acting on behalf of or at the direction of these 3 entities, in connection with debt issued by them before  March 1, 2022.
• amended general license concerning “Continuation of Business and Basic Needs of GEFCO U.K. Subsidiaries” to permit persons or a relevant institution to process payments or transactions related to the sale and transfer of the Joint Venture’s shares by Russian Railways. This license expires on May 23, 2022.
• amended general license concerning ‘Russian Banks – UK subsidiaries – ‘Basic needs, routine holding and maintenance, the payment of legal fees and insolvency related payments’ to allow any payments, or take any actions, in connection with the Insolvency Proceedings relating to VTB Capital’s UK subsidiary.  This license expires on March 1, 2023.