Sanctions Developments Resulting From the Conflict in Ukraine - European Union

July 6, 2023

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Table of Contents:

Asset Freezes and Travel Bans

The European Union announced that a series of individuals and entities are subject to an asset freeze and travel ban.

  • On February 23, 2022, the European Union published sanctions designations for 336 members[1] of the Russian legislature who voted to recognize the independence of the DNR and LNR and 26 other individuals and entities[2] – including VEB, PSB, Rossiya and Internet Research Agency – for asset freezes.  With respect to the newly targeted banks (VEB, PSB and Rossiya), EU Member State authorities may authorize, until August 24, 2022, the release and making available of funds and economic resources necessary to terminate operations, contracts or other agreements (including correspondent banking relations) concluded with the designated banks before February 23, 2022.
  • On February 25, 2022, the European Union published the additional designations of Russian President Putin, Russian Minister of Foreign Affairs Sergei Viktorovich Lavrov and 95 other individuals and entities, including individuals who facilitated Russian military operations from Belarus, for asset freezes.[3]  Unlike the February 23, 2022 designations, these designations do not allow EU Member States to authorize wind down transactions.
  • Also on February 25, 2022, the European Union published visa restrictions according to which Russian diplomats, other officials and certain business personnel will no longer be able to benefit from the existing EU visa facilitation provisions (including privileged access to the European Union).[4]
  • On February 28, 2022, the European Union published the additional designations of 26 individuals, described as Russian “oligarchs and businessmen,” government members, military officials and “propagandists,” and one entity, Gas Industry Insurance Company SOGAZ, for asset freezes and, for the natural persons, travel bans.[5]  Unlike the February 23, 2022 designations, these designations do not expressly allow EU Member States to generally authorize wind down transactions (though other licensing regimes may still be applicable) and the sanctions take effect immediately.
  • On March 2, 2022, the European Union published the additional designations of 22 Belarusian military and defence officials for asset freezes.[6]
  • On March 9, 2022, the European Union published additional designations of 146 members of the Russian Federation Council who ratified the “Treaty of Friendship, Cooperation and Mutual Assistance between the Russian Federation and the Donetsk People’s Republic and between the Russian Federation and the Luhansk People’s Republic” and 14 individuals supporting, benefitting from, providing a substantial source of revenue to or associated with the Russian government, for asset freezes.[7]
  • On March 15, 2022, the European Union published additional designations of 15 individuals (including Roman Abramovich and several Russian state-controlled media outlet officials) and 9 entities (including Rosneft Aero, Rosoboroneksport, High Precision Systems, Kurganmashzavod, Russian Helicopters, United Aircraft Corporation, United Shipbuilding Corporation, Uralvagonzavod and Zelenodolsk Shipyard) for asset freezes.[8]
  • On April 8, 2022, the European Union published additional designations of 217 individuals and 18 entities, including Ministers and members of the “People’s Council” of the so-called “Donetsk People’s Republic” and “Luhansk People’s Republic” and well as leading businesspersons and entities such as Bank Otkritie, Novikombank, Sovcombank, and VTB.[9]
  • On June 3, 2022, the European Union published additional designations of 65 individuals and 18 entities, including political and business figures, high-ranking military officers and entities involved in the military, manufacturing equipment and software sectors[10]. On the same day, the European Union published additional designations of 12 Belarusian individuals and of 8 Belarussian entities involved in the potash and tobacco industries, transport and logistics or television and radio broadcasting[11].
  • On October 6, 2022, the European Union published sanctions designations of 30 individuals and 7 entities - whom the Union considers responsible for actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine - for asset freezes.[12]

    The European Union also introduced a new listing criterion specifically targeting the facilitation (including by non-EU persons) of infringements of the prohibition against circumvention of the provisions under the EU sanctions framework.  This allows the addition of natural or legal persons to the list of persons and entities (i) subject to asset freeze measures,[13] and (ii) subject to Member States necessary measures to prevent their entry into, or transit through, their territories.[14]
  • On February 25, 2023, the European Union published additional sanctions designations of 87 individuals and 34 entities including Russian decision-makers, senior government officials and military leaders[15]. The listed entities include, among others, three banks (Rosbank, Tinkoff Bank and Alfa-Bank), the Russian National Reinsurance Company, the Russian National Wealth Fund as well as companies manufacturing military equipment. For the first time, a third- country entity, a shipping company registered in the United Arab Emirates, has been listed.

    The 10th package also detailed requirements for natural and legal persons to provide information on individuals and entities subject to asset freezing measures within two weeks[16].
  • On June 23, 2023, the European Union published additional sanctions designations of 71 individuals and 33 entities including members of the Russian military and defence sector, individuals connected to deportations of Ukrainian children and looting of Ukraine’s cultural heritage, media executives, propagandists and other individuals responsible for disinformation, members of the judiciary who took politically motivated decisions, businesspersons, a deputy minister, a number of Russian local officials and two banks.[17]

The European Union also introduced further derogation options from the asset freeze and prohibition to make funds and economic resources available to designated persons and entities. 

  • On April 8, 2022, the European Union announced that:
    • Member States can authorize the release of frozen funds for payments to be used for official purposes of the diplomatic mission, consular post or international organisation; and
    • The release of these funds can also be authorized for payments used for funds/economic resources that are necessary for the sale and transfer by 9 October 2022 of proprietary rights in a EU person or entity whose proprietary rights are owned by a designated person or entity. The derogation clearly provides that the proceeds of the sale or transfer must remain frozen.[18]  
  • On the same day, the European Union announced that an authorisation to release certain frozen funds or resources belonging to:
    • Rossiya, Promsvyazbank, and VEB can be granted if appropriate and necessary for those entities to terminate by August 24, 2022 the operations, contracts and other agreements, concluded with those entities before 23 February 2022; and
    • Otkritie FC Bank (formerly Nomos), Novikombank, Sovcombank (formerly Buycombank) and VTB Bank can be granted if appropriate and necessary for those entities to terminate by October 9, 2022 the operations, contracts and other agreements, concluded with those entities before 8 April 2022.[19]
  • On April 13, 2022, the European Union announced that:
  • The prohibition to make available funds and economic resources of listed individuals and entities does not apply to funds and economic resources made available by entities “pillar-assed” by the European Union and with which it has signed a financial framework partnership agreement to act as humanitarian partners of the European Union.  The provision of funds must be necessary for exclusively humanitarian purposes in Ukraine; and
  • Member States can grant specific or general authorizations to release frozen assets if these are necessary for exclusively humanitarian purposes in Ukraine.[20]
  • On June 23, 2023, the European Union announced that:
    • Member States may authorise the release of certain frozen funds/economic resources belonging to certain specified designated entities (including, for example, the National Settlement Depository), or the making available of certain funds/economic resources to such entities, where (a) this is necessary for the disposal/transfer of securities by an EU entity currently or previously controlled by VTB Bank, (b) such disposal/transfer is completed by 31 December 2023, and (c) such disposal/transfer is carried out on the basis of operations, contracts or other agreements concluded before 3 June 2022.[21]
    • Member States may authorise the conversion by 25 December 2023 by EU nationals/entities of a depositary receipt with Russian underlying security held with the National Settlement Depository for the purpose of selling the underlying security, and the making available of funds linked to the conversion of the depositary receipt and to the sale of the underlying security directly or indirectly to that entity in Russia, under such conditions as the competent authorities deem appropriate and after having determined that: (a) the depositary receipt was issued before 3 June 2022; (b) the relevant request for authorisation is submitted by 25 September 2023; (c) the holder of the depositary receipt is able to demonstrate that such conversion is necessary for the sale of the underlying security; (d) the sale of the underlying security is compliant with prohibitions under Regulation No 833/2014, including Articles 5 and 5f; and (e) no funds will be made available to any other sanctioned entity.[22]
    • Competent authorities may authorise the release of certain frozen funds or economic resources belonging to Alexey Alexandrovits Mordashov, or the making available of certain funds or economic resources to Mordashov or an entity owned by Mordashov, under such conditions as the competent authorities deem appropriate and after having determined that such making available of funds or economic resources to them is necessary for the completion of transactions, including sales, which are strictly necessary for the wind-down, by 31 August 2023, of a joint venture or similar legal arrangement established in Russia with Mordashov or an entity owned by Mordashov before 28 February 2022.[23]
    • Competent authorities may authorise the release of certain frozen funds or economic resources belonging to, owned, held or controlled by a sanctioned natural or legal person, entity or body, or the provision of services to such a natural or legal person, entity or body, under such conditions as they deem appropriate and after having determined that this is strictly necessary for the setting-up, certification or evaluation of a firewall which: (a) removes the control by the sanctioned natural or legal person, entity or body over the assets of a non-listed EU entity which is owned or controlled by the former; and (b) ensures that no further funds or economic resources accrue for the benefit of the sanctioned natural or legal person, entity or body.[24]

Competent authorities may authorise the release of certain frozen funds or economic resources belonging to certain specified sanctioned entities, or the making available of certain funds or economic resources to those entities, under such conditions as the competent authorities deem appropriate and after having determined that such funds or economic resources are necessary for the purchase, import or transport of agricultural and food products, including wheat and fertilisers.[25]

Financial Sector Sanctions

On February 25, 2022, the European Union published a package of restrictive measures against Russia that includes:[26]

  • An extension of the existing financial restrictions in place against Russia, in particular those regarding access by certain Russian entities to EU capital markets.  The restrictions now apply to newly sanctioned Alfa Bank, Bank Otkritie, Rossiya, PSB, Almaz-Antey, Kamaz, Novorossiysk Commercial Sea Port, Rostec, Russian Railways, JSC PO Sevmash, Sovcomflot and United Shipbuilding Corporation (including their non-EU subsidiaries)[27].  The package further expands the scope of restrictions applicable to entities previously subject to sectoral sanctions and, in particular, restrict dealings with all transferable securities and money market instruments issued by the sanctioned entities after April 12, 2022 and restrict making any new loans and credit after February 26, 2022 irrespective of their maturity.
  • The introduction of measures that:
    • prohibit the listing and provision of services in relation to the transferable securities of Russian state-owned entities on trading venues registered or recognized in the EU after April 12, 2022; and
    • limit the financial inflows from Russia to the European Union by prohibiting (i) the acceptance after April 12, 2022 of deposits exceeding EUR 100,000 per credit institution from Russian nationals or residents, or legal persons established in Russia (unless the deposits are necessary for non-prohibited cross border trade in goods and services between the Union and Russia) with the ability for EU Member States to authorize exemptions in a limited number of cases, (ii) the EU central securities depositories from providing any services for transferable securities issued after April 12, 2022 to any Russian national or resident or a legal person established in Russia, and (iii) the sale of Euro-denominated transferable securities issued after April 12, 2022 to Russian nationals or residents or any legal person established in Russia.
      • These restrictions do not apply to nationals of an EU Member State or natural persons having a temporary or permanent residence permit in an EU Member State. 

On February 28, 2022, the European Union published an amendment to the preexisting EU sanctions regulations regarding Russia to prohibit transactions related to the management of the reserves as well as the assets of the Russian Central Bank (however, unlike the similar U.S. and UK measures, this amendment does not address the Russian Ministry of Finance or the Russian National Wealth Fund).[28]  This prohibition covers transactions with any legal person, entity or body acting on behalf of, or at the direction of, the Russian Central Bank.  The amendment provides an exception for transactions strictly necessary to ensure the financial stability of the European Union as a whole or a specific EU Member State concerned with a transaction.  While certain public announcements suggested that this prohibition was aimed only at preventing the Russian Central Bank from accessing the foreign reserves it had accumulated prior to the conflict in Ukraine, the recitals to the amendment suggest that the intention may have been to “prohibit any transactions with the [Russian Central Bank].”  However, since the amendment does not designate the Russian Central Bank for an asset freeze, the exact scope of the prohibition remains somewhat unclear.

On March 2, 2022, the European Union published an amendment to the preexisting EU sanctions regulations regarding Russia that include the below restrictions (one of these amendments also includes SWIFT-related restrictions that are discussed in the “SWIFT” section below).  The amendment prohibits:

  • The supply of Euro-denominated banknotes to Russian persons or entities (including the Russian government and the Russian Central Bank), or for use in Russia, with the exception of when the relevant banknotes are necessary for (1) the personal use of natural persons travelling to Russia or members of their immediate families travelling with them, or (2) the official purposes of diplomatic missions enjoying immunities under to international law; and
  • The investment, participation or contribution in other forms in or to projects co‑financed by the RDIF.[29]
    • The relevant amendment permits EU Member States to authorize (under conditions they deem appropriate) such investment, participation or contribution due under contracts concluded before March 2, 2022.

On March 9, 2022, the European Union published additional sectoral measures targeting the Belarusian financial sector (one of the measures is SWIFT-related restrictions that are discussed in the “SWIFT” section below).[30]  The measures include: 

  • The expansion of existing measures by prohibiting the listing and provision of services in relation to shares of Belarus state-owned entities on EU trading venues (as of April 12, 2022);
  • The prohibition on transactions with the Central Bank of Belarus relating to the management of its reserves or assets and the provision of public financing for trade with and investment in Belarus (subject to certain limited exceptions);
  • The prohibition on the acceptance of deposits exceeding EUR 100,000 from Belarusian nationals or residents, the holding of accounts of Belarusian clients by the EU central securities depositories and the selling of Euro-denominated securities to Belarusian clients; and
  • The prohibition on the provision of Euro-denominated banknotes to Belarus.

On the same day, the European Union also published measures including: 

  • The expansion, to the maritime sector, of the list of legal persons, entities and bodies subject to the prohibitions related to investment services, transferable securities, money market instruments and loans; and
  • The clarification that the notion of “transferable securities” includes digital assets (in order to ensure proper implementation of the measures published on February 25, 2022).[31]

On March 15, 2022, the European Union published additional sectoral measures targeting investments and financial services in Russia.[32]  The measures include: 

  • A prohibition on new investments by EU companies in the Russian energy sector, including Russian oil companies;
  • A prohibition on all transactions with certain Russian state-owned companies (including OPK Oboronprom, United Aircraft Corporation, Uralvagonzavod, Rosneft, Transneft, Gazprom Neft, Almaz-Antey, Kamaz, Rostec, JSC PO Sevmash, Sovcomflot, United Shipbuilding Corporation) with certain limited exceptions; and
  • A prohibition on the provision of credit rating services and subscription services in relation to credit rating activities to Russian clients starting on April 15, 2022.

On April 8, 2022, the European Union published additional financial measures targeting Russian[33] and Belarusian[34] banks and financial services.  These measures include:

  • The extension to all official currencies of EU Member States of the prohibitions on the export of euro-denominated banknotes and on the sale of euro-denominated transferrable securities; and
  • A ban on the provision of crypto-asset services exceeding EUR 10,000 to Russia.

On June 3, 2022, the European Union published additional sectoral measures targeting services to the Russian state and Russian companies.  These measures include a ban on providing auditing, accounting, tax, management consulting or public relations services. Contracts concluded before the sanctions have to be concluded by July 5 with the possibility of derogation on a case-by-case basis[35].

On October 6, 2022, the European Union published additional sectoral measures targeting services to the Russian state and Russian companies.  These measures include

  • A ban on providing architectural and engineering services, legal advisory services and IT consultancy services. Contracts concluded before the sanctions have to be wound down by January 8 2023, with the possibility of derogation on a case-by-case basis[36].
  • A tightening of the existing prohibitions on crypto assets by banning all crypto-asset wallets, accounts, or custody services, irrespective of the amount of the wallet, removing the previous threshold of €10,000.[37]
  • The addition of the Russian Maritime Register to the list of state-owned companies subject to a transaction ban. [38]

On February 25, 2023, the European Union published measures introducing an additional reporting obligation for individuals and entities on the reserves and assets of the Russian Central Bank[39].

On June 23, 2023, the European Union published measures extending the prohibition on providing transferable securities to persons in Russia to financial instruments denominated in any currency.[40]

Trade Restrictions

On February 25, 2022, the European Union published a package of export control measures against Russia that includes:[41]

  • Energy Sector Sanctions:  The package prohibits the sale, supply, transfer or export, directly or indirectly, of certain oil refining-related goods and technologies, whether or not originating in the EU, to Russia or for use in Russia, and additional measures will be introduced that will restrict the provision of related services.  The prohibitions do not apply to execution until May 27, 2022 of contracts concluded before February 26, 2022, or ancillary contracts necessary for the execution of such contracts.
  • Transportation Sector Sanctions:  The package introduces a ban on the direct or indirect sale, supply, transfer or export of goods and technology suited for use in the aviation and space industries, whether or not originating in the EU, to Russia or for use in Russia, as well as a prohibition on the provision of insurance and reinsurance, maintenance services and technical and financial assistance related to such goods and technology.  The list of covered goods includes aircraft, spacecraft and their components.  The prohibitions do not apply to the execution until March 28, 2022 of contracts concluded before February 26, 2022, or ancillary contracts necessary for the execution of such contracts.
  • Technology Sector Sanctions:  The package imposes further restrictions on the export of dual-use goods and technology to Russia and other goods and technology which might contribute to Russia’s technological enhancement of its defence and security sector.[42]  These measures cover equipment related to the manufacturing of electronic components and materials and other specially designed components and accessories.  The package includes limited exemptions for certain legitimate and pre-determined purposes.  The list of the affected goods and technology includes equipment for the manufacture of electronic components or materials and specially designed components and accessories therefore.  Affected parties must request licence authorizations from an EU Member State before May 1, 2022 to authorize exports related to contracts concluded before February 26, 2022.

On March 2, 2022, the European Union published additional export control restrictions regarding Belarus.  The restrictions affect the trade of goods used for the production or manufacturing of tobacco products, mineral fuels, bituminous substances and gaseous hydrocarbon products, potassium chloride (“potash”) products, wood products, cement products, iron and steel products and rubber products, dual-use goods and technology, and certain advanced goods and technology which might contribute to Belarus’ military, technological, defence and security development, along with restrictions on the provision of related services.[43]

On March 15, 2022, the European Union published additional trade restrictions that include:

  • An expansion of the list of persons connected to Russia’s defense and industrial sectors on whom tighter export restrictions regarding dual-use goods and technology as well as goods and technology which might contribute to the technological enhancement of Russia’s defense and security sectors are imposed;
  • An export restriction on equipment, technology and services for the Russian energy sector, with an exception for nuclear energy and downstream energy transportation activities;[44]
  • A prohibition on selling, supplying, transferring or exporting luxury goods with a value of more than €300 to Russia (with certain goods – for example, electronic items and vehicles – subject to higher value thresholds); and
  • A ban on the direct or indirect import of Russian steel and iron.[45]

On March 15, 2022, the European Union also announced that it would seek:

  • The revocation of Russia’s most favoured nation (MFN) status at the World Trade Organization which could lead to further restrictions via customs duties and import quotas;
  • The suspension of Russia’s membership rights of leading multilateral institutions, including the International Monetary Fund and the World Bank; and
  • The suspension of Belarus’ World Trade Organization application.[46]

On April 8, 2022, the European Union announced:

  • An extension of the list of controlled items which might contribute to Russia’s military and technological enhancement;
  • Import restrictions on goods which generate significant revenues for Russia including cement, rubber products, wood, spirits, liquor, seafood (as of August 10, 2022 for contracts concluded before April 9, 2022);
  • Import restrictions on coal and other solid fossil fuels into the European Union of they originate in Russia or are exported from Russia (as of August 10, 2022 for contracts concluded before April 9, 2022);
  • Export restrictions to Russia on jet fuels and other goods such as quantum computers and advanced semiconductors, high-end electronics, software, sensitive machinery and transportation equipment; and
  • Export restrictions on goods which could contribute in particular to the enhancement of Russian industrial capacities (as of July 10, 2022 for contracts concluded before April 9, 2022).

The fifth package does provide for authorizations to be exempted from these prohibitions for products such as coal (and other solid fossil fuels),[47] natural gas and oil (including refined petroleum products), as well as titanium, aluminium, copper, nickel, palladium and iron ore purchased, imported or transported from or through Russia into the Union. These products benefit from:

  • A derogation to the prohibition to directly or indirectly engage in any transaction with Russian entities until 10 August 2022.
  • A derogation to the prohibition to award or continue the execution of any public or concession contract with Russian entities is added until 10 August 2022.

On the same day, the EU also published additional sanctions in the transport sector:[48]

  • A full ban on Russian and Belarusian freight road operators to transport goods by road in the EU (with exemptions covering agricultural and food products, humanitarian aid and energy). Derogations via an authorization are possible when such transport is necessary for the purchase, import or transport gas, oil, certain metals but also pharmaceutical, medical, agricultural and food products.
  • An entry ban on Russian-flagged vessels to EU ports after April 16, 2022.  This ban includes vessels susceptible to have changed their flag or registration after 24 February 2022.  Derogations are provided when such vessels need access to an EU port to purchase, import or transport gas, oil, certain metals, chemical products or nuclear fuel for civil capabilities.  The Regulation also provides exemptions for products with, amongst others, medical, agricultural and food or humanitarian purposes.

On June 3, 2022, the European Union published additional export restrictions against Russia and Belarus that includes[49]:

  • An export ban on additional chemicals that could be used in the process of manufacture of chemical weapons and high-tech goods.
  • An extension of the list of persons and entities concerned by export restrictions on dual-use goods and technologies to include persons and entities involved in various sectors such as electronics, communications, weapons, shipyards, engineering and scientific research.  The list of Belarusian entities subject to restrictions expands from 1 to 25 entities[50].
  • The addition of the United Kingdom and the Republic of Korea to the Annex of partner countries that have adopted substantially equivalent export restrictions.

On the same day, the EU also published sanctions in the energy sector with restrictions on oil imports and oil transport services[51]:

  • A ban on imports of crude oil and petroleum products originating in or exported from Russia. This ban applies only to imports by sea at this stage with transition periods of 6 months for crude oil and 8 months for refined products (8 months transition period as well for re-export of petroleum products from crude oil processing within the EU).  There are specific temporary derogations for some Member States (Croatia, Bulgaria, Czech Republic). Import of oil from third countries via Russia is allowed, subject to certain conditions.
  • A ban on the provision of insurance and financing services related to the transportation of Russian or exported crude oil or oil products from Russia after a 6-month transition period.

On October 6, 2022, the European Union published additional trade measures relating to Russia:

  • A ban on the export of coal including coking coal, specific electronic components found in Russian weapons, technical items used in the aviation sector, as well as certain chemicals. [52]  
  • A ban on the import of Russian finished and semi-finished steel products, machinery and appliances, plastics, vehicles, textiles, footwear, leather, ceramics, certain chemical products, and non-gold jewellery. [53]
  • The additional measures also include an exemption from the prohibition to provide technical assistance, brokering services or financing or financial assistance, related to the maritime transport to third countries of crude oil or petroleum products which originate in or are exported from Russia, purchased at or below a pre-established price cap agreed by the Price Cap Coalition.[54]

On February 25, 2023, the European Union published additional trade restrictions against Russia that include[55]:

  • An extended export ban on dual use goods and sensitive technology to target new items such as additional electronic components used in weapons systems or specific rare earths.
  • Extended export bans on types of goods which can be redirected to the war effort. For example, the list of goods which could contribute to the Russian industrial capacities now includes items such as alloy or non-alloy steel products or stream and vapour turbines and items such as turbojets are added to the list of goods and technology used in the aviation industry.
  • A new exception to the export ban for specific goods or services strictly necessary to produce titanium goods required in the aeronautics industry when no alternative supply is available.
  • The prohibition of transit through Russia of EU exported dual-use goods and technology as well as arms. This measure seeks to address the circumvention of existing restrictions in this area.
  • Additional bans, covering about 1.3 billion euros of imports of bitumen and related materials such as asphalt, synthetic rubber and carbon blacks. Contracts concluded before the entry into force of the package can be executed until 27 May 2023. Carbon and rubber specifically are subject to an import quota until 30 June 2024.
  • A clarification allowing customs authorities to release goods  physically brought, in good faith, in the Union which had already been presented to customs authorities when they became subject to restrictions.

On June 23, 2023, the European Union published additional trade restrictions against Russia that include[56]:

  • A prohibition on the sale, license or transfer in any other way of intellectual property rights or trade secrets, as well as the granting of rights to access or re-use any material or information protected by means of intellectual property rights or constituting trade secrets, in relation to the goods and technology whose sale, supply, transfer or export, to a person, entity or body in Russia or for use in Russia is prohibited.
  • An extension of the prohibition on the transport of goods by road in the EU to cover transport of goods by trailers and semi-trailers registered in Russia, including when those trailers or semi-trailers are hauled by trucks registered outside of Russia.
  • Regarding the ban on the importation of iron and steel products processed in a third country incorporating iron and steel products originating in Russia, a clarification as to the evidence required: at the moment of importation, importers shall provide evidence of the country of origin of the iron and steel inputs used for the processing of the product in a third country.

SWIFT/Financial Messaging Services Sanctions

On February 26, 2022, the United States, the European Commission, France, Germany, Italy, the United Kingdom and Canada jointly announced a commitment to ensuring that “selected Russian banks” are removed from the SWIFT financial messaging service.  The announcement also indicated that an international task force will be established to ensure the effective implementation of international sanctions and asset freezes on Russia, and that the group of countries would coordinate to counter disinformation and hybrid warfare.[57]

On March 2, 2022, the European Union published an amendment to the preexisting EU sanctions regulations regarding Russia that prohibits, as of March 12, 2022, EU-based parties (including, most notably, the Belgium-based SWIFT) from providing specialized financial messaging services to seven designated Russian banks (Otkritie, Novikombank, PSB, Rossiya, Sovcombank, VEB and VTB Bank) and any of those banks’ directly or indirectly more than 50%-owned Russian subsidiaries.[58]

On March 9, 2022, the European Union extended the restrictions on the provision of specialized financial messaging services (including, most notably, SWIFT) to three Belarusian credit institutions (Belagroprombank, Bank Dabrabyt and the Development Bank of the Republic of Belarus) and their Belarusian subsidiaries.[59]

On June 3, 2022, the European Union extended the restrictions on SWIFT to three additional Russian banks[60] (Sberbank, Credit Bank of Moscow and Rosselkhozbank) and one additional Belarussian bank[61].

These sanctions mean that the designated Russian banks cannot use the SWIFT financial messaging service to facilitate banking transactions.  Subject to any other applicable sanctions, these Russian banks can still engage in such banking transactions, but those banking transactions must be coordinated through other means.

Other Measures

On February 28, 2022, the European Union published an amendment to the preexisting EU sanctions regulations regarding Russia that prohibits all Russian-owned, Russian-registered and Russian-controlled aircraft from landing in, taking off from and flying through the European Union.[62]  The amendment provides exceptions for (1) emergency landings and overflights, and (2) landings and overflights related to humanitarian purposes or any other purpose consistent with the relevant EU regulations.

On March 2, 2022, an additional package of sanctions includes media sector sanctions.  The amendment prohibits operators from broadcasting, or enabling, facilitating or otherwise contributing to the broadcast of, including through transmission by cable, satellite, IP-TV, internet service providers, video-sharing platforms or applications, new or pre-installed, any content by certain designated Russia media entities (including five “Russia Today (RT)” entities and “Sputnik”).  The amendment also suspends the designated entities’ broadcasting licences, authorisations and transmission/distribution arrangements.

On April 8, 2022, the European Union’s fifth package of sanctions also includes:[63]

  • Russian nationals and entities established in Russia (with limited exceptions where there is no viable alternative);
  • owned or controlled entities from EU, Euratom and Member State programmes (with limited exemptions). This includes all ongoing grant agreements to Russian public bodies or related entities, all related payments, under Horizon 2020 and Horizon Europe, Euratom, and Erasmus+ and restrictions on all new contracts or agreements with Russian public bodies or related entities these programmes;
  • A prohibition to register, provide an office or an address or advice to trusts having as a trustor or beneficiary Russian nationals, legal entities established in Russia, and legal entities owned for more than 50% by a Russian person or entity. It is also prohibited to act or arrange for another person to act as, a trustee, nominee shareholder, director, secretary (or similar positions) for these entities as of May 10, 2022.  These prohibitions do not apply to operations that are necessary for the termination by May 10, 2022, of contracts concluded before April 9, 2022.

On June 3, 2022, the European Union’s sixth package of sanctions includes[64]:

  • Refined measures on trusts and added certain exceptions (humanitarian purposes, promotion of democracy and human rights and operation of trusts with specified purposes such as occupational pension schemes).
  • A ban on the three major Russian public broadcasters (Rossiya RTR / RTR Planeta, Rossiya 24 / Russia 24, TV Centre International) to broadcast content in the EU and on advertising on sanctioned Russian media.

On October 6, 2022, the European Union’s eighth package of sanctions includes:

  • A ban on Union nationals to hold any posts on the governing bodies of those legal persons, entities or bodies.[65]

On February 25, 2023, the European Union’s tenth package of sanctions includes:

  • A prohibition for Russian nationals and entities from booking gas storage capacity with a transitional period ending on March 27, 2023 to execute all operations necessary to terminate existing or ancillary contracts. The prohibition does not cover liquefied natural gas (LNG)[66].
  • A ban on Russian nationals from serving on governing bodies of Member States’ critical infrastructure companies. This ban does not extend to EU, EEA or Swiss nationals[67].
  • The additions of the Arab language subsidiaries of Russia Today and Sputnik to the media ban[68] prohibiting them, among other things, from broadcasting, enabling, facilitating or otherwise contributing to the broadcast of, any content.

On June 23, 2023, the European Union’s eleventh package of sanctions includes:

  • An extension of the requirements for Member State competent authorities to exchange information with each other in order to avoid forum shopping, including on any authorisation granted or denied; in the event of suspected forum shopping or other cases as appropriate, on requests for authorisation received; infringements and penalties; best practices of national enforcement authorities and the detection and prosecution of unauthorised export.
    • A number of measures to fight circumvention of the EU’s sanctions, including:
    • An amendment to the existing listing criteria, to include natural or legal persons, entities or bodies significantly frustrating restrictive measures or facilitating infringements of the prohibition against circumvention of the EU’s restrictive measures.[69]
    • A prohibition on the transit via the territory of Russia of goods and technology which might contribute to Russia’s military and technological enhancement or to the development of its defence and security sector, goods and technology suited for use in aviation or space industry and jet fuel and fuel additives, exported from the Union. [70] 
    • A framework for prohibiting the sale, supply, transfer or export of certain goods and technology to third countries whose jurisdiction is demonstrated to be at a continuing and particularly high risk of being used for circumvention. Such restrictions, described as “exceptional, last-resort measures”, would be preceded by several procedural steps, including a brief of the Council on technical details of circumvention issues in question, outreach and other alternative measures taken and trade data demonstrating that those measures have been ineffective, and enforcement measures. The EU should also inform and actively seek the views of the government of the relevant third country on the basis of the preliminary findings set out in the technical analysis by the Commission and the EU’s intended remedial action. [71]
    • A prohibition, as of 24 July 2023, to provide access to ports and locks in the EU territory by any vessel which the competent authority has reasonable cause to suspect of illegally interfering with, switching off or otherwise disabling its shipborne automatic identification system at any point of the voyage to a Member State’s ports or locks, in breach of SOLAS Regulation V/19, point 2.4, when transporting crude oil or petroleum products subject to existing trade restrictions.[72]

***

The European Commission regularly publishes practical guidelines in a FAQ format on most aspects of sanctions[73].

***

Special thanks to Tristan Favaletto from our Brussels office, for his assistance on this project.

[1] Council Decision (CFSP) 2022/267 of 23 February 2022 amending Decision 2014/145/CFSP concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, 2022 OJ (L 42I) 114.

[2] Council Decision (CFSP) 2022/267 of 23 February 2022 amending Decision 2014/145/CFSP concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, 2022 OJ (L 42I) 98.

[3] Council implementing Regulation (EU) 2022/332 of 25 February 2022 implementing Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, available at https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32022R0332&from=EN.

[4] Council Decision (EU) 2022/333 of 25 February 2022 on the partial suspension of the application of the Agreement between the European Community and the Russian Federation on the facilitation of the issuance of visas to the citizens of the European Union and the Russian Federation, available at https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32022D0333&from=EN.

[5] European Council, “Russia’s military aggression against Ukraine: Council imposes sanctions on 26 persons and one entity” (Feb. 28, 2022), available at https://www.consilium.europa.eu/en/press/press-releases/2022/02/28/russia-s-military-aggression-against-ukraine-council-imposes-sanctions-on-26-persons-and-one-entity/.

[6] Council Decision (CFSP) 2022/354 of 2 March 2022 amending Decision 2014/145/CFSP concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, available at https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv%3AOJ.L_.2022.066.01.0014.01.ENG&toc=OJ%3AL%3A2022%3A066%3AFULL.

[7] Council Implementing Regulation (EU) 2022/396 of 9 March 2022 implementing Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine and Council Decision (CFSP) 2022/397 of 9 March 2022 amending Decision 2014/145/CFSP concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, available at https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=OJ:L:2022:080:FULL&from=EN. 

[8] Council Implementing Regulation (EU) 2022/427 of 15 March 2022 implementing Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, available at https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32022R0427&from=EN.

[9] Council regulation (EU) 2022/581 of 8 April 2022 implementing Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, available at: https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32022R0581&from=EN.

[10] Council implementing regulation (EU) 2022/878 of 3 June 2022 implementing Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, available at: https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32022R0878&from=EN

[11] Council implementing regulation (EU) 2022/876 of 3 June 2022 implementing Article 8a(1) of Regulation (EC) No 765/2006 concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine, available at: https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32022R0876&from=EN#d1e32-3-1

[12] Council Implementing Regulation (EU) 2022/1906 of 6 October 2022 implementing Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, 2022 OJ (L 259I) 79.

[13] Council Regulation (EU) 2022/1905 of 6 October 2022 amending Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions  undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, 2022 OJ (L 259I) 76.

[14] Council Decision (CFSP) 2022/1907 of 6 October 2022 amending Decision 2014/145/CFSP concerning restrictive measures in respect of actions  undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, 2022 OJ (L 259I) 98.

[15] Council Implementing Regulation (EU) 2023/429 of 25 February 2023 implementing Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, available at: https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32023R0429&from=EN

[16] Council Regulation (EU) 2023/426 of 25 February 2023 amending Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, available at: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv%3AOJ.LI.2023.059.01.0001.01.ENG&toc=OJ%3AL%3A2023%3A059I%3ATOC

[17] Council Implementing Regulation (EU) 2023/1216 of 23 June 2023 implementing Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, available at: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv%3AOJ.LI.2023.159.01.0335.01.ENG&toc=OJ%3AL%3A2023%3A159I%3AFULL

[18] Council Regulation (EU) 2022/580 of 8 April 2022 amending Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, available at: https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32022R0580&from=EN.

[19] Council Regulation (EU) 2022/580 of 8 April 2022 amending Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, available at: https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32022R0580&from=EN.

[20] Council regulation (EU) 2022/625 of 13 April 2022 amending Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, available at https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32022R0625&from=EN.

[21] Council Regulation (EU) 2023/1215, Article 1(2)(a) (replacing Article 6b(5a) of Regulation (EU) No 269/2014).

[22] Council Regulation (EU) 2023/1215, Article 1(2)(b) (inserting a new Article 6b(5aa) in Regulation (EU) No 269/2014).

[23] Council Regulation (EU) 2023/1215, Article 1(2)(c) (inserting a new Article 6b(5c) in Regulation (EU) No 269/2014).

[24] Council Regulation (EU) 2023/1215, Article 1(2)(d) (inserting a new Article 6b(5d) in Regulation (EU) No 269/2014).

[25] Council Regulation (EU) 2023/1215, Article 1(3) (replacing Article 6e(1) in Regulation (EU) No 269/2014).

[26] Council regulation (EU) 2022/328 of 25 February 2022 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilizing the situation in Ukraine, available at https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=OJ:L:2022:049:FULL&from=EN.

[27] The sanctions also apply to banks previously made subject to sectoral sanctions, i.e., Sberbank, VTB Bank, Gazprombank, VEB, Rosselkhozbank, OPK Oboronprom, United Craft Corporation, Ural Vagonzavod, Rosneft, Transneft and Gazpromneft.  PSB and Bank Rossiya are separately subject to the asset freezes according to the earlier announced measures.

[28] Council Regulation (EU) (2022/334) of 28 February 2022 amending Council Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, available at https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ:L:2022:057:FULL&from=EN.

[29] Council Regulation (EU) (2022/345) of 1 March 2022 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine available at https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32022R0345&from=EN.

[30] Council Regulation (EU) 2022/398 of 9 March 2022 amending Regulation (EC) No 765/2006 concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine and Council Decision (CFSP) 2022/399 of 9 March 2022 amending Decision 2012/642/CFSP concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine, available at https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32022R0398&from=EN. 

[31] Council Regulation (EU) 2022/394 of 9 March 2022 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine and Council Decision (CFSP) 2022/395 of 9 March 2022 amending Decision 2014/512/CFSP concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, available at https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=OJ:L:2022:081:TOC

[32] Council Regulation (EU) 2022/428 of 15 March 2022 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, available at https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32022R0428&from=EN.

[33] Council Regulation (EU) 2022/576 of 8 April 2022 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine available at: https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32022R0576&from=EN.

[34] Council Regulation (EU) 2022/577 of 8 April 2022 amending Regulation (EC) No 765/2006 concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine, available at: https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32022R0577&from=EN.

[35] Council Regulation (EU) 2022/879 of 3 June 2022 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, available at https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32022R0879&from=EN#d1e787-53-1

[36] Council Regulation (EU) 2022/879 of 3 June 2022 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, available at https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32022R0879&from=EN#d1e787-53-1

[37] Council Decision (CFSP) 2022/1909 of 6 October 2022 amending Decision 2014/512/CFSP concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, available here https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=OJ:L:2022:259I:FULL&from=EN.

[38] Council Decision (CFSP) 2022/1909 of 6 October 2022 amending Decision 2014/512/CFSP concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, available here https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=OJ:L:2022:259I:FULL&from=EN.

[39] Council Regulation (EU) 2023/427 of 25 February 2023 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, available at: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv%3AOJ.LI.2023.059.01.0006.01.ENG&toc=OJ%3AL%3A2023%3A059I%3ATOC

[40] Council Regulation (EU) 2023/1214 of 23 June 2023 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, available at: https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32023R1214.

[41] Council Regulation (EU) 2022/328 of 25 February 2022 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilizing the situation in Ukraine, available at https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=OJ:L:2022:049:FULL&from=EN.

[42] The European Commission published practical guidelines in a Q&A available at: https://trade.ec.europa.eu/doclib/press/index.cfm?id=2371.

[43] Council Regulation (EU) (2022/355) of 2 March 2022 amending Regulation (EC) No 765/2006 concerning restrictive measures in view of the situation in Belarus, available at https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32022R0355.

[44] The fifth package of sanctions further extended the exemption of the prohibition to engage in transactions with certain State-owned entities as regards transactions for the purchase, import or transport of fossil fuels and certain minerals into Switzerland, the European Economic Area and the Western Balkans.  See Council Regulation (EU) 2022/576 of 8 April 2022 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine available at: https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32022R0576&from=EN.

[45] Council Regulation (EU) 2022/428 of 15 March 2022 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv%3AOJ.LI.2022.087.01.0013.01.ENG&toc=OJ%3AL%3A2022%3A087I%3ATOC.

[46] Council of the EU Press release of 15 March 2022, available at https://www.consilium.europa.eu/en/press/press-releases/2022/03/15/russia-s-military-aggression-against-ukraine-fourth-eu-package-of-sectoral-and-individual-measures/.

[47] As listed in Annex XXII of Regulation 833/2014.

[48] Council Regulation (EU) 2022/576 of 8 April 2022 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine available at: https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32022R0576&from=EN and Council Regulation (EU) 2022/577 of 8 April 2022 amending Regulation (EC) No 765/2006 concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine, available at: https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32022R0577&from=EN.

[49] Council Regulation (EU) 2022/879 of 3 June 2022 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, available at https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32022R0879&from=EN#d1e787-53-1

[50] Council Regulation (EU) 2022/877 of 3 June 2022 amending Regulation (EU) No 765/2006 concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine, available at: https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32022R0877&from=EN

[51] Council Regulation (EU) 2022/879 of 3 June 2022 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, available at https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32022R0879&from=EN#d1e787-53-1

[52] Council Regulation (EU) 2022/1904 of 6 October 2022 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, available at https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=OJ:L:2022:259I:FULL&from=EN.

[53] Council Regulation (EU) 2022/1904 of 6 October 2022 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, available at https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=OJ:L:2022:259I:FULL&from=EN.

[54] Council Decision (CFSP) 2022/1909 of 6 October 2022 amending Decision 2014/512/CFSP concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, available here https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=OJ:L:2022:259I:FULL&from=EN.

[55] Council Regulation (EU) 2023/427 of 25 February 2023 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, available at: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv%3AOJ.LI.2023.059.01.0006.01.ENG&toc=OJ%3AL%3A2023%3A059I%3ATOC

[56] Council Regulation (EU) 2023/1214 of 23 June 2023 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, available at: https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32023R1214

[57] White House, “Joint Statement on Further Restrictive Economic Measures” (Feb. 26, 2022), available at https://www.whitehouse.gov/briefing-room/statements-releases/2022/02/26/joint-statement-on-further-restrictive-economic-measures/.

[58] Council Regulation (EU) (2022/345) of 1 March 2022 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine available at https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32022R0345&from=EN.

[59] Council Regulation (EU) (2022/398) of 9 March 2022 amending Regulation (EC) No 765/2006 concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine, available at https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32022R0398&from=EN.

[60] Council Regulation (EU) 2022/879 of 3 June 2022 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, available at https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32022R0879&from=EN#d1e787-53-1

[61] Council Regulation (EU) 2022/877 of 3 June 2022 amending Regulation (EU) No 765/2006 concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine, available at: https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32022R0877&from=EN

[62] Council Regulation (EU) (2022/334) of 28 February 2022 amending Council Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, available at https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ:L:2022:057:FULL&from=EN.

[63] Council Regulation (EU) 2022/576 of 8 April 2022 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, available at: https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32022R0576&from=EN.

[64] Council Regulation (EU) 2022/879 of 3 June 2022 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, available at https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32022R0879&from=EN#d1e787-53-1

[65] Council Decision (CFSP) 2022/1909 of 6 October 2022 amending Decision 2014/512/CFSP concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, available here https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=OJ:L:2022:259I:FULL&from=EN.

[66] Council Decision (CFSP) 2023/434 of 25 February 2023 amending Decision 2014/512/CFSP concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, available at: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv%3AOJ.LI.2023.059.01.0593.01.ENG&toc=OJ%3AL%3A2023%3A059I%3ATOC

[67] Council Regulation (EU) 2023/427 of 25 February 2023 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, available at: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv%3AOJ.LI.2023.059.01.0006.01.ENG&toc=OJ%3AL%3A2023%3A059I%3ATOC

[68] Council Decision (CFSP) 2023/434 of 25 February 2023 amending Decision 2014/512/CFSP concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, available at: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv%3AOJ.LI.2023.059.01.0593.01.ENG&toc=OJ%3AL%3A2023%3A059I%3ATOC

[69] Council Regulation (EU) 2023/1215 of 23 June 2023 amending Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, available at: https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32023R1215.

[70] Council Regulation (EU) 2023/1214 of 23 June 2023 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, available at: https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32023R1214

[71] Council Regulation (EU) 2023/1214 of 23 June 2023 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, available at: https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32023R1214

[72] Council Regulation (EU) 2023/1214 of 23 June 2023 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, available at: https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32023R1214

[73] The European Commission FAQs are available at: https://ec.europa.eu/info/business-economy-euro/banking-and-finance/international-relations/restrictive-measures-sanctions/sanctions-adopted-following-russias-military-aggression-against-ukraine_en