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The US, EU, UK, Canada and Australia have continued to enact additional sanctions packages in response to Russia’s invasion of Ukraine. In this post, we outline some of the measures imposed since our last update.
Our previous updates on sanctions imposed on Russia in relation to its activities in Ukraine can be found here, here, here, here and here.
On 25 February 2022, the US imposed sanctions on Russian President Vladimir Putin, Russian Foreign Minister Sergey Lavrov, Russian Minister of Defense Sergei Shoigu and Chief of the General Staff of the Russian Armed Forces Valery Gerasimo These individuals have been added to the SDN list.
On 28 February 2022:
On 25 February 2022, the EU agreed on a further sanctions package targeting various sectors of the Russian economy and also senior political and military leaders in Russia and Belarus.
This new package includes the following measures:
As of 28 February 2022, no aircraft operated by any Russian air carrier may land in, take off from or overfly EU territory.
The UK announced on 25 and 28 February 2022 that it would be introducing legislation to align its Russia sanctions program with that of its multilateral partners. The measures announced include:
In a demonstration of its post-Brexit sanctions powers, the UK has issued a number of US-style General Licences to facilitate the wind down of activities affected by these prohibitions.
In a letter issued to UK ports on 28 February 2022, the Transport Secretary, possibly in anticipation of the introduction of further restrictive measures, advised ports to refuse any ship that they believe to be owned, controlled, chartered or operated by any person connected with Russia or a sanctioned person or flagged or registered in Russia.
On February 25, 2022, the Canadian Prime Minister announced that Canada would join its multilateral partners in imposing sanctions directly on Russian President Vladimir Putin and his inner circle of advisers, including Foreign Minister Sergei Lavrov and Chief of the General Staff Valery Gerasimov.
The Canadian government subsequently announced:
Since our last update, Australia has imposed further measures to further align its sanctions policy with its multilateral partners.
On 26 February 2022, further targeted financial sanctions and travel bans were passed with an effective date of 27 February in respect of:
On 27 February, the Australian Government imposed sanctions on President Putin, and four of his senior officials: Sergei Lavrov (Foreign Minister), Vladimir Kolokoltsev (Minister for Internal Affairs), Mikhail Mishustin (Prime Minister) and Sergei Shoigu (Defence Minister). These designations came into effect on Monday, 28 February.
Since our last update, the US, EU, UK, and others, have indicated that they intend to “remove certain Russian banks from the SWIFT messaging system”. As the measures giving effect to this objective take shape over the coming days, we have considered the implications of such a step in a separate post.
The US, EU, UK, and others are broadly aligned, from a policy objective, in terms of the effect that the latest package of sanctions seeks to achieve. However, from a sanctions compliance and risk mitigation perspective, the extent of any nuances or divergence in the respective legislative text (particularly as between the UK and EU) will be of interest for multinational companies trading across these jurisdictions.
As we continue to monitor and update you on development, we encourage readers to subscribe to be kept informed of new developments.