Two Months On: EU & U.K. Continue Expanding Russia Sanctions

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Authors: James Ellis-Rees

Two months into Russia’s invasion of Ukraine, the EU and the U.K. have continued to expand their Russia sanctions programs. Here we summarise the measures introduced since our previous update and we overview where the EU and U.K. programs are since the invasion started on 24 February.

EU Announcements Since 6 April

21 April: Asset freezes against Serhiy Vitaliyovich Kurchenko and Yevgeniy Viktorovich Prigozhin
13 April: Humanitarian exemptions made to certain existing asset freezes and trade restrictions
11 April: Twenty Russian airlines made subject to operating bans or restrictions on safety grounds
8 April: Asset freezes against 217 individuals and 18 entities, including all 179 members of the so-called governments and parliaments of Donetsk and Luhansk, oligarchs and business people and family members, and the following financial, military, industrial and transportation entities:
- JSC Arzamas Machine-Building Plant
- JSC Ruselectronics
- JSC Tacitical Missiles Corporation
- JSC Kalashnikov Concern
- JSC UEC Klimov
- LLC Military Industrial Company
- PO More Shipyard
- JSC Omsk Transport Machine Factory Omsktransmash
- JSC Russian Machines
- JSC Sozvezdie Concern
- JSC Research and Industrial Concern “Machine Engineering Technologies” — JSC RIC TECMASH
- PJSC United Engine Corporation
- Yantar Shipyard
- Otkritie FC Bank
- Novikombank
- Sovcombank
- VTB Bank
- JSC GTLK

U.K. Announcements Since 6 April

21 April: Asset freezes against 16 individuals and the following 10 entities:
- Aleksandrov Scientific Research Technological Institute NITI
- Central Research Institute of Machine Building JSC
- Federal Sate Unitary Enterprise Dukhov Automatics Research Institute
- JSC Arzamas Machine-Building Plant
- JSC GTLK
- JSC Kalashnikov Concern
- LLC Military Industrial Company
- Promtech-Dubna JSC
- Radiotechnical and Information Systems Concern
- Rocket and Space Centre Progress JSC
21 April: General licence granted allowing payments to Gazprombank under existing gas contracts until 31 May 2022
14 April: The Russia (Sanctions) (EU Exit) (Amendment) (No 8) Regulations 2022 introduced:
- Export prohibitions on luxury goods to Russia or persons connected with Russia
- Prohibitions on imports/acquisitions of iron and steel products from Russia and supply of such products to third countries
- Prohibitions on export of oil refining and quantum computing goods or technology to Russia or persons connected with Russia
14 April: The Russia (Sanctions) (Overseas Territories) (Amendment) Order 2022 extended the U.K. Russia sanctions to British overseas territories
14 April: Asset freezes against Eugene Tenenbaum and David Davidovich (associates of Roman Abramovich)
13 April: Asset freezes against 206 individuals involved in destabilising Ukraine, undermining its territorial integrity or supporting the government of Russia
8 April: Asset freezes against Katerina Vladimirovna Tikhonova and Maria Vladimirovna Vorontsova (daughters of Vladimir Putin) and Yekaterina Sergeyevna Vinokurova (daughter of Sergei Lavrov)
6 April: Asset freezes against eight individuals and two entities involved in destabilising Ukraine, undermining its territorial integrity or supporting the government of Russia:
- Viatcheslav (Moshe) Kantor
- Andrey Guryev
- Sergey Kogogin
- Sergei Sergeivich Ivanov
- Leonid Mikhelson
- Andrey Akimov
- Alexander Dyukov
- Boris Borisovich Rotenberg
- Credit Bank of Moscow
- PJSC Sberbank
6 April: General licence granted allowing the winding down of transactions involving Credit Bank of Moscow until 6 May 2022; Sberbank added to the existing general licence allowing energy-related payments

Overview of EU and U.K. Russia Sanctions Measures
Individuals	Asset freezes and travel restrictions for designated individuals and entities

Financial	Restricted access to primary and secondary capital markets for certain Russian banks and companies
	Prohibition on transactions with the Russian Central Bank and the Central Bank of Belarus
	SWIFT ban for certain Russian and Belarusian banks
	Prohibition on the provision of euro-denominated banknotes to Russia and Belarus
	Prohibition on public financing or investment in Russia
	Prohibition on investment in and contribution to projects co-financed by the Russian Direct Investment Fund

Energy	Prohibition on coal imports from Russia
	Prohibition of exports of oil refining goods and technology to Russia
	Prohibition on new investments in Russian energy sector

Transport	Closure of airspace to Russian-owned and Russian-registered aircraft
	Closure of ports to Russian vessels
	Prohibition on Russian and Belarusian road transport operators
	Prohibition on exports to Russia of aviation, maritime and space industry goods and technology

Defence	Prohibition on exports to Russia of dual-use goods and technology items that could contribute to defence and security capabilities
	Prohibition on trade in arms

Raw Materials and Other Goods	Prohibition on imports from Russia of iron, steel, wood, cement, seafood and liquor

Luxury Goods	Prohibition on exports of luxury goods

Media	Prohibition on broadcasts by Russian state-owned media

Crimea and Sevastopol, Donetsk and Luhansk	Import ban on goods
	Restrictions on trade and investment
	Export ban on certain goods and technologies