Sanctions Developments Resulting From the Conflict in Ukraine - Other Jurisdictions

April 22, 2022

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Table of Contents:

Australia

Australia has extended its territorial sanctions (which previously applied to Crimea and Sevastopol) to the so-called Donetsk People’s Republic (“DNR”) and the so-called Luhansk People’s Republic (“LNR”).  These sanctions prohibit trade in the transport, energy, telecommunications, and oil, gas and minerals sectors.[1]

Australia has imposed targeted financial sanctions (similar to EU and UK asset freezes) on:

  • Russian government and military officials, including Russian President Vladimir Putin, Sergei Lavrov, Vladimir Kolokoltsev, Mikhail Mishustin, Sergei Shoigu, Dmitry Grigorenko, Maxim Reshetnikov, and Aleksander Babakov, 339 members of the Russian Parliament, members of the Security Council, and senior Russian military commanders, including Mikhail Mizintsev;[2]
  • Russian government entities, including the Central Bank of Russia, Russian Ministry of Finance, and Russian National Wealth Fund;[3]
  • Russian state-owned entities, including Kamaz, SEVMASH, United Shipbuilding Corporation, Ruselectronics, and Russian Railways;[4]
  • Russian financial institutions, including Sberbank, Gazprombank, VEB, VTB Bank, Rosselkhozbank, Sovcombank, Novikombank, Alfa-Bank, and Credit Bank of Moscow;[5]
  • Russian businesspeople (so-called “oligarchs”) including Roman Abramovich, Chelsea Football Club owner, Alexey Miller, CEO of Gazprom, Dmitri Lebedev, Chairman of Rossiya, Sergey Chemezov, Chair of Rostec, Nikolay Tokarev, CEO of Transneft, Igor Shuvalov, Chairman of VEB and Kirill Dmitriev, CEO of RDIF, Oleg Deripaska, Founder of Basic Element, and Viktor Veskelberg, owner and president of Renova Group;[6]
  • a number of “propagandists and disinformation operatives;”[7]
  • Kremlin-connected leaders in Ukraine, including “so-called mayor of Melitopol” Galina Danilchenko and Oleg Voloshyn;[8] and
  • Belarusian individuals and entities providing support to Russia, including President Alexander Lukashenko and his family.[9]

Australia has prohibited Australian individuals and entities from doing business with Rossiya, IS Bank, GenBank, PSB, and the Black Sea Bank and from investing in VEB.[10]

Australia has prohibited the export of alumina, bauxite, and luxury goods to Russia, including wine, high value cosmetics and parts for luxury vehicles.[11]

Australia has supported the removal of identified Russian banks from SWIFT and imposed restrictions on the Russian Central Bank’s use of its reserves.[12]

Canada

Canada has imposed a general ban on dealings with “the non-government controlled areas of” the DNR and LNR.[13]

Canada has imposed asset freezes, which prohibit persons in Canada or Canadians wherever located from dealing in any property held by or on behalf of a designated person, in addition to prohibiting facilitating or providing financial (or other related) services related to such dealings,[14] on:

  • Current and former Russian government officials, including President Vladimir Putin, Foreign Minister Sergei Lavrov, Minister of Defence Sergei Shoigu, Minister of Justice Konstantin Chuychenko, Finance Minister Anton Siluanov, other members of Russia’s Security Council, members of the Russian legislature who voted to recognize the independence of the DNR and LNR, and 160 members of the Russian Federation Council;[15]
  • Close associates and family members of sanctioned members of the Russian government, individuals, and oligarchs, including Roman Abramovich, Leonid Viktorovich Mikhelson, and Vladimir Olegovich Potanin, and “agents of disinformation;” [16]
  • Ten executives working for Rosneft or Gazprom;[17]
  • Russian government or government-owned entities, including the Central Bank of the Russian Federation, the National Wealth Fund, and the Russian Ministry of Finance;[18]
  • Significant Russian financial institutions, including Sberbank, VEB, and Promsvyazbank PJSC;[19]
  • 22 senior officials of Belarus’s Department of Defense;[20] and
  • Russian entities in the defense sector.[21]

Canada has imposed a general ban on dealings in Russian Federation sovereign debt.[22]

Canada has enacted wide-ranging restrictions on exports to Russia, which:

  • Bar 32 defense entities, most of which are owned by or have contracts with the Russian government, from receiving defense equipment or supplies from Canada;[23] and
  • Prohibit export of items in the areas of electronics, computers, telecommunications, sensors and lasers, navigation and avionics, marine, aerospace and transportation.[24]

Canada has restricted the importation of specific petroleum products from Russia, including crude oil.[25]

Canada has prohibited any ship registered, used, leased or chartered, in whole or in part, by or on behalf of Russia, a person in Russia, or designated person from docking in Canada or passing through Canadian waters,[26] and the provision of all insurance, reinsurance, and underwriting services for aircraft, aviation, and aerospace products owned, controlled, registered, chartered, or operated by entities and individuals resident, incorporated, or domiciled in Russia.[27]

Cayman Islands and British Virgin Islands

The United Kingdom’s Russia sanctions regime is extended to designated British Overseas Territories, including the Cayman Islands and British Virgin Islands, by the Russia (Sanctions) (Overseas Territories) Order 2020.[28]  Accordingly, Cayman Islands and British Virgin Islands persons and entities are required to comply with the UK sanctions measures on Russia – including the asset freezes – discussed in the overview of UK Sanctions.[29]

Channel Islands (Jersey and Guernsey)

The Channel Islands (Jersey and Guernsey) implement UK sanctions programs.  Accordingly, Jersey and Guernsey persons and entities are required to comply with the UK sanctions measures on Russia – including the asset freezes – discussed in the overview of UK Sanctions.[30]

However, at the time of publication of this blog post, the general licenses that have been issued by the United Kingdom are applicable to (and may be relied upon by persons and entities in) Guernsey, but are not applicable to Jersey.

Germany

Germany has announced that it would take administrative action to stop the certification of the Nord Stream 2 pipeline, which the German government says will prevent the pipeline from becoming operational.[31]

Japan

Japan has imposed asset freezes on:

  • Officials from the DNR and LNR;[32]
  • Russian financial institutions, including VEB, PSB, Rossiya, VTB Bank, Bank Otkritie, Sovcombank, Novicombank, Sberbank, and Alfa Bank;[33]
  • Russian individuals, including President Vladimir Putin and Viktor Vekselberg;[34] and
  • Russian entities, including Rosoboronexport.[35]

Japan has imposed restrictions on the issuance and trading of new Russian sovereign debt.[36] 

Additionally, Japan has banned all new Japanese investment in Russia.[37]

Japan has stripped Russia of its “most favored nation” trade status[38] and expanded its export restrictions to Russia (and to Belarus[39]), which include:

  • A ban on any exports to and from the DNR and LNR;[40]
  • A ban on exports to Russian military-related entities, the Armed Forces of Belarus, or of items considered to strengthen Russia’s or Belarus’s military capabilities;[41]
  • A prohibition on the export of oil refining equipment to Russia;[42]
  • Export controls or prohibitions on more than 300 designated items and technologies;[43]
  • Prohibitions on exports to an additional 81 Russian organizations;[44]
  • A ban on luxury car, jewelry, art, cosmetics, liquor, and gold exports to Russia;[45]
  • A ban on imports of Russian products, including machinery, wood, and vodka;[46]
  • A phase-out of imports of coal;[47] and
  • Increased duties on certain imports (including food products) from Russia until March 2023.[48]

Japan announced it would revise its foreign exchange law to close loopholes for Russian companies’ cryptocurrency assets.[49]

New Zealand

New Zealand has imposed asset freezes (and travel bans, if imposed on an individual) on:

  • Russian government officials, including Russian President Vladimir Putin and 12 members of his Security Council; [50]
  • Other Russian political, economic, and military elites, such as Roman Abramovich;[51]
  • Russian government-affiliated financial institutions, including the Russian Central Bank, the Russia Agricultural Bank, and the Russian Direct Investment Fund;[52] and
  • Other major Russian financial institutions, including Alfa-Bank, Bank Rossiya, Bank Otkritie, Black Sea Bank for Development and Reconstruction, Credit Bank of Moscow, Gazprombank, GenBank, Industrial Savings Bank, Novikombank, PSB, Russian National Commercial Bank, Sberbank, Sovcombank, SMP Bank, Vnesheconombank, and VTB Bank.[53]

New Zealanders and New Zealand-based businesses are also prohibited from dealing in the securities of the above-listed sanctioned persons, if doing so would result in sanctioned persons acquiring, owning, or controlling the relevant securities or being otherwise benefited.[54]

The Prime Minister of New Zealand announced that New Zealand would prohibit the export of goods to the Russian military and security forces,[55] apply a 35% tariff to all imports from Russia, and prohibit exports of industrial products closely connected to strategic Russian industries, such as ICT equipment and engines, to Russia and Belarus.[56]

The Prime Minister of New Zealand also announced the New Zealand government would close New Zealand sea and airspace to Russian and Belarusian vessels and planes.[57]

Norway

Norway has imposed wide-ranging sanctions which correspond to the restrictive measures imposed by the European Union through March 15, 2022 (excluding the EU sanctions against Russia Today and Sputnik),[58] which include:

  • Prohibitions on transactions with designated Russian state-owned enterprises;
  • A ban on new investments in the Russian energy sector;
  • Prohibitions against the provision of credit rating services to any Russian persons or entities;
  • Trade restrictions on the import of iron and steel products; and
  • Export restrictions on luxury goods and on products, technology, and services related to the energy industry.

Singapore

Singapore has imposed sanctions applicable to financial institutions in Singapore, though the prohibitions do not apply to processing or facilitating payments that are necessary for basic expenses of designated banks and entities (i.e., insurance premiums, reasonable fees for property management or technology-related services, remuneration, taxes, rent, etc.).[59]  The prohibited activities include:

  • Transacting with VTB Bank, VEB, PSB or Rossiya (in addition to freezing the assets of these banks);
  • Facilitating fundraising by the Russian government, the Russian Central Bank or any entity owned or controlled by the Russian government or the Russian Central Bank;
  • Providing financial services in the DNR and LNR related to transportation, telecommunications, energy and mining; and
  • Facilitating transactions in cryptocurrencies to avoid any of the listed prohibitions.[60]

Singapore announced export control restrictions on Russia with respect to military goods, electronics, computers, telecommunications, and dual-use goods.[61]

South Korea

South Korea announced a prohibition on transactions with the Russian Central Bank.[62]

South Korea has banned the export of strategic items, including electronics, semiconductors, computers, information and communications, sensors and lasers, navigation and avionics, and marine and aerospace equipment, to Russia.[63]  The Ministry of Foreign Affairs in South Korea announced that South Korea will implement similar export control measures against Belarus.[64] 

South Korea has supported excluding Russian banks from SWIFT.[65] 

Switzerland

Switzerland has largely adopted sanctions measures mirroring those adopted by the EU, including:

  • Asset freezes on (including a ban on entering into new business relationships with) certain designated individuals and entities, including Russian President Putin, Russian Prime Minister Mikhail Mishustin and Russian Minister of Foreign Affairs Sergei Viktorovich Lavrov, individuals with close ties to Russian President Putin, 197 other individuals including prominent oligarchs and business people, and nine entities;[66]
  • A travel/entry ban applying to designated individuals with connections to Switzerland and direct ties to Russian President Putin;[67]
  • Restrictions on transactions with certain Russian state-owned enterprises;[68]
  • Restrictions on participating in, or providing loans (or other financial resources) and rating services to, businesses in the Russian energy sector, [69] and
  • Prohibitions on the provision of public financing or financial assistance for trade with or investment in Belarus and transactions with the Belarusian Central Bank.[70]

Switzerland has banned the participation of Russian companies in public procurement and prohibited financial support for Russian public institutions.[71]

Switzerland has adopted export and trade restrictions mirroring those adopted by the EU, including:

  • A ban on imports, exports and investments from and into the DNR and LNR (i.e., the extension of the existing ban regarding Crimea to the DNR and LNR);[72]
  • A ban on the export of luxury goods; [73]
  • A ban on the export of goods and services for use in the Russian energy sector;[74]
  • A ban on the import of iron and steel goods, coal, wood, cement, seafood, and vodka from Russia;[75]
  • A ban on the export of dual-use items and the import of wood products, rubber products, iron and steel, and cement from Belarus;[76] and
  • An export ban on kerosene, industrial robots, certain chemicals, and other goods that could strengthen Russia’s industrial capacity.[77]

Switzerland has adopted restrictions regarding financing messaging services similar to those adopted by the European Union on March 1, 2022.[78]

Taiwan

Taiwan has announced export rules to prevent technology and chips from being used for military purposes.  These rules now prohibit export of 57 strategic high-tech products to Russia,[79] unless the exporter applies to the Bureau of Foreign Trade and receives approval.[80]  The export-controlled items[81] include:

  • Telecommunications equipment;
  • Integrated circuit parts;
  • Variable-frequency drives;
  • Equipment for making semiconductors;
  • Lasers; and
  • Navigation systems.

[1] Prime Minister of Australia, “Australia’s response to Russia’s aggression against Ukraine” (Feb. 23, 2022), available at https://www.pm.gov.au/media/australias-response-russias-aggression-against-ukraine.

[2] Autonomous Sanctions (Designated Persons and Entities and Declared Persons—Russia and Ukraine) Amendment (No. 2) Instrument 2022 (Feb. 27, 2022), available at https://www.legislation.gov.au/Details/F2022L00194; Autonomous Sanctions (Designated Persons and Entities and Declared Persons-Ukraine) Amendment (No. 4) Instrument 2022 (Feb. 25, 2022), available at https://www.legislation.gov.au/Details/F2022L00192; Prime Minister of Australia, “Australia’s response to Russia’s aggression against Ukraine” (Feb. 23, 2022), available at https://www.pm.gov.au/media/australias-response-russias-aggression-against-ukraine; Minister for Foreign Affairs of Australia, “Further sanctions on Russia” (Mar. 8, 2022), available at https://www.foreignminister.gov.au/minister/marise-payne/media-release/further-sanctions-russia; Minister for Foreign Affairs of Australia, “Further Russia Sanctions” (Apr. 7, 2022, available at https://www.foreignminister.gov.au/minister/marise-payne/media-release/further-russia-sanctions.

[3] Minister for Foreign Affairs of Australia, “New sanctions on Russian banks and oligarchs” (Mar. 18, 2022), available at https://www.foreignminister.gov.au/minister/marise-payne/media-release/new-sanctions-russian-banks-and-oligarchs.

[4] Minister for Foreign Affairs of Australia, “Additional sanctions on Russian state-owned enterprises” (Apr. 14, 2022), available at https://www.foreignminister.gov.au/minister/marise-payne/media-release/additional-sanctions-russian-state-owned-enterprises#:~:text=The%20Australian%20Government%20has%20imposed,SEVMASH%20and%20United%20Shipbuilding%20Corporation.

[5] Minister for Foreign Affairs of Australia, “New sanctions on Russian banks and oligarchs” (Mar. 18, 2022), available at https://www.foreignminister.gov.au/minister/marise-payne/media-release/new-sanctions-russian-banks-and-oligarchs.

[6] Minister for Foreign Affairs of Australia, “Australia joins the UK and US in sanctioning key Russian oligarchs” (Mar. 14, 2022), available at https://www.foreignminister.gov.au/minister/marise-payne/media-release/australia-joins-uk-and-us-sanctioning-key-russian-oligarchs; Minister for Foreign Affairs of Australia, “New sanctions on Russian banks and oligarchs” (Mar. 18, 2022), available at https://www.foreignminister.gov.au/minister/marise-payne/media-release/new-sanctions-russian-banks-and-oligarchs

[7] Minister for Foreign Affairs of Australia, “New sanctions on Russian banks and oligarchs” (Mar. 18, 2022), available at https://www.foreignminister.gov.au/minister/marise-payne/media-release/new-sanctions-russian-banks-and-oligarchs

[8] Minister for Foreign Affairs of Australia, “Further Russia Sanctions” (Apr. 7, 2022, available at https://www.foreignminister.gov.au/minister/marise-payne/media-release/further-russia-sanctions.

[9] Autonomous Sanctions (Designated Persons and Entities and Declared Persons—Russia and Ukraine) Amendment (No. 1) Instrument 2022 (Feb. 26, 2022), available at https://www.legislation.gov.au/Details/F2022L00193; Minister for Foreign Affairs of Australia, “Australia places additional sanctions on Russia and Belarus” (Mar. 25, 2022), available at https://www.foreignminister.gov.au/minister/marise-payne/media-release/australia-places-additional-sanctions-russia-and-belarus.

[10] Prime Minister of Australia, “Australia’s response to Russia’s aggression against Ukraine” (Feb. 23, 2022), available at https://www.pm.gov.au/media/australias-response-russias-aggression-against-ukraine; Prime Minister of Australia, “Australia’s response to Russia’s aggression against Ukraine” (Feb. 23, 2022), available at https://www.pm.gov.au/media/australias-response-russias-aggression-against-ukraine.

[11] Minister for Foreign Affairs of Australia, “Luxury Exports Ban to Russia” (Apr. 5, 2022), available at https://www.foreignminister.gov.au/minister/marise-payne/media-release/luxury-exports-ban-russia.

[12] Minister for Foreign Affairs of Australia, “Economic measures against Russia and lethal military equipment for Ukraine” (Feb. 28, 2022), available at https://www.foreignminister.gov.au/minister/marise-payne/media-release/economic-measures-against-russia-and-lethal-military-equipment-ukraine.

[13] Prime Minister of Canada, “Canada announces support to address the situation in Ukraine” (Feb. 22, 2022), available at https://pm.gc.ca/en/news/news-releases/2022/02/22/canada-announces-support-address-situation-ukraine; Prime Minister of Canada, “Canada announces support to address the situation in Ukraine” (Feb. 22, 2022), available at https://pm.gc.ca/en/news/news-releases/2022/02/22/canada-announces-support-address-situation-ukraine.

[14] Government of Canada, “Types of Sanctions,” available at https://www.international.gc.ca/world-monde/international_relations-relations_internationales/sanctions/types.aspx?lang=eng (accessed Apr. 6, 2022); Special Economic Measures (Russia) Regulations, SOR/2014-58, available at https://laws.justice.gc.ca/eng/regulations/sor-2014-58/fulltext.html.

[15] Prime Minister of Canada, “Canada announces support to address the situation in Ukraine” (Feb. 22, 2022), available at https://pm.gc.ca/en/news/news-releases/2022/02/22/canada-announces-support-address-situation-ukraine; Regulations Amending the Special Economic Measures (Russia) Regulations (Feb. 28, 2022), available at https://www.international.gc.ca/world-monde/international_relations-relations_internationales/sanctions/russia_regulations-reglement_russie3.aspx?lang=eng; Regulations Amending the Special Economic Measures (Russia) Regulations (Feb. 28, 2022), available at https://www.international.gc.ca/world-monde/international_relations-relations_internationales/sanctions/russia_regulations-reglement_russie4.aspx?lang=eng; Regulations Amending the Special Economic Measures (Russia) Regulations (Mar. 23, 2022), available at https://www.international.gc.ca/world-monde/international_relations-relations_internationales/sanctions/russia_regulations-reglement_russie11.aspx?lang=eng; Regulations Amending the Special Economic Measures (Russia) Regulations (Mar. 14, 2022), available at https://www.international.gc.ca/world-monde/international_relations-relations_internationales/sanctions/russia_regulations-reglement_russie10.aspx?lang=eng.

[16] Regulations Amending the Special Economic Measures (Russia) Regulations (Mar. 6, 2022), available at https://www.international.gc.ca/world-monde/international_relations-relations_internationales/sanctions/russia_regulations-reglement_russie6.aspx?lang=eng; Regulations Amending the Special Economic Measures (Russia) Regulations (Mar. 10, 2022), available at https://www.international.gc.ca/world-monde/international_relations-relations_internationales/sanctions/russia_regulations-reglement_russie9.aspx?lang=eng; Regulations Amending the Special Economic Measures (Russia) Regulations (Apr. 5, 2022), available at https://www.international.gc.ca/world-monde/international_relations-relations_internationales/sanctions/russia_regulations-reglement_russie13.aspx?lang=eng; Regulations Amending the Special Economic Measures (Russia) Regulations, SOR/2022-084 (Apr. 19, 2022), available at https://www.international.gc.ca/world-monde/international_relations-relations_internationales/sanctions/russia_regulations-reglement_russie15.aspx?lang=eng.

[17] Regulations Amending the Special Economic Measures (Russia) Regulations (Mar. 4, 2022), available at https://www.international.gc.ca/world-monde/international_relations-relations_internationales/sanctions/russia_regulations-reglement_russie5.aspx?lang=eng.

[18] Regulations Amending the Special Economic Measures (Russia) Regulations (Feb. 28, 2022), available at https://www.international.gc.ca/world-monde/international_relations-relations_internationales/sanctions/russia_regulations-reglement_russie3.aspx?lang=eng; Regulations Amending the Special Economic Measures (Russia) Regulations (Feb. 28, 2022), available at https://www.international.gc.ca/world-monde/international_relations-relations_internationales/sanctions/russia_regulations-reglement_russie4.aspx?lang=eng.

[19] Prime Minister of Canada, “Canada announces support to address the situation in Ukraine” (Feb. 22, 2022), available at https://pm.gc.ca/en/news/news-releases/2022/02/22/canada-announces-support-address-situation-ukraine; Regulations Amending the Special Economic Measures (Russia) Regulations, SOR/2022-027, (Feb. 24, 2022), available at https://www.international.gc.ca/world-monde/international_relations-relations_internationales/sanctions/russia_regulations-reglement_russie2.aspx?lang=eng; Regulations Amending the Special Economic Measures (Russia) Regulations, SOR/2022-029, (Feb. 24, 2022), available at https://www.international.gc.ca/world-monde/international_relations-relations_internationales/sanctions/russia_regulations-reglement_russie.aspx?lang=eng.

[20] Regulations Amending the Special Economic Measures (Belarus) Regulations (Mar. 16, 2022), available at https://www.international.gc.ca/world-monde/international_relations-relations_internationales/sanctions/belarus_regulations-reglement2.aspx?lang=eng.

[21] Regulations Amending the Special Economic Measures (Russia) Regulations, SOR/2022-081, (Apr. 8, 2022), available at https://www.international.gc.ca/world-monde/international_relations-relations_internationales/sanctions/russia_regulations-reglement_russie14.aspx?lang=eng.

[22] Prime Minister of Canada, “Canada announces support to address the situation in Ukraine” (Feb. 22, 2022), available at https://pm.gc.ca/en/news/news-releases/2022/02/22/canada-announces-support-address-situation-ukraine; Prime Minister of Canada, “Canada announces support to address the situation in Ukraine” (Feb. 22, 2022), available at https://pm.gc.ca/en/news/news-releases/2022/02/22/canada-announces-support-address-situation-ukraine.

[23] Regulations Amending the Special Economic Measures (Russia) Regulations (Mar. 10, 2022), available at https://www.international.gc.ca/world-monde/international_relations-relations_internationales/sanctions/russia_regulations-reglement_russie8.aspx?lang=eng.

[24] Regulations Amending the Special Economic Measures (Russia) Regulations (Mar. 24, 2022), available at https://www.international.gc.ca/world-monde/international_relations-relations_internationales/sanctions/russia_regulations-reglement_russie12.aspx?lang=eng.

[25] Government of Canada, “Government of Canada Moves to Prohibit Import of Russian Oil” (Feb. 28, 2022), available at https://www.canada.ca/en/natural-resources-canada/news/2022/02/government-of-canada-moves-to-prohibit-import-of-russian-oil.html; Regulations Amending the Special Economic Measures (Russia) Regulations (Mar. 10, 2022), available at https://www.international.gc.ca/world-monde/international_relations-relations_internationales/sanctions/russia_regulations-reglement_russie8.aspx?lang=eng.

[26] Regulations Amending the Special Economic Measures (Russia) Regulations (Mar. 6, 2022), available at https://www.international.gc.ca/world-monde/international_relations-relations_internationales/sanctions/russia_regulations-reglement_russie7.aspx?lang=eng.

[27] Regulations Amending the Special Economic Measures (Russia) Regulations (Apr. 5, 2022), available at https://www.international.gc.ca/world-monde/international_relations-relations_internationales/sanctions/russia_regulations-reglement_russie13.aspx?lang=eng.

[28] The Russia (Sanctions) (Overseas Territories) Order 2020, available at https://www.legislation.gov.uk/uksi/2020/1571/contents.

[29] Cleary Foreign Investment and International Trade Watch, “Sanctions Developments Resulting From the Conflict in Ukraine - United Kingdom,” available at https://www.clearygottlieb.com/news-and-insights/publication-listing/sanctions-developments-resulting-from-the-geopolitical-conflict-in-ukraine---united-kingdom.

[30] Cleary Foreign Investment and International Trade Watch, “Sanctions Developments Resulting From the Conflict in Ukraine - United Kingdom,” available at https://www.clearygottlieb.com/news-and-insights/publication-listing/sanctions-developments-resulting-from-the-geopolitical-conflict-in-ukraine---united-kingdom.

[31] “Germany halts Nord Stream 2 and Russia responds with a stark warning,” CNN (Feb. 23, 2022), available at https://www.cnn.com/2022/02/22/‌business/nord-stream-2-germany-russia/index.html.

[32] Ministry of Foreign Affairs of Japan, “Sanction Measures following Russia’s Recognition of the ‘Independence’ of the ‘Donetsk People’s Republic’ and the ‘Luhansk People’s Republic’ and the ratification of treaties with the two ‘Republics’” (Feb. 24, 2022), available at https://www.mofa.go.jp/press/release/press4e_003085.html; Ministry of Foreign Affairs of Japan, “Foreign Exchange and Foreign Trade Law Measures Concerning the Situation in Ukraine” (Mar. 3, 2022), available at https://www.mofa.go.jp/mofaj/press/release/press4_009291.html.

[33] Ministry of Foreign Affairs of Japan, “Sanction Measures following the launch of military actions by Russia in Ukraine (Statement by Foreign Minister HAYASHI Yoshimasa)” (Feb. 25, 2022), available at https://www.mofa.go.jp/press/release/press6e_000371.html; “Japan imposes more sanctions on Russia, Belarus,” Japan Today (Mar. 8, 2022), available at https://japantoday.com/category/politics/update1-japan-imposes-more-sanctions-on-russia-belarus-over-ukraine-invasion; Ministry of Foreign Affairs of Japan, “Foreign Exchange and Foreign Trade Law Measures Concerning the Situation in Ukraine” (Mar. 3, 2022), available at https://www.mofa.go.jp/mofaj/press/release/press4_009291.html; “Japan OKs asset freezes on Putin’s daughters, 396 other Russians,” Kyodo News (Apr. 12, 2022), available at https://english.kyodonews.net/news/2022/04/c3def6cb040f-urgent-japan-oks-asset-freezes-on-398-russians-incl-putins-daughters.html.

[34] Ministry of Foreign Affairs of Japan, “Foreign Exchange and Foreign Trade Law Measures Concerning the Situation in Ukraine” (Mar. 3, 2022), available at https://www.mofa.go.jp/mofaj/press/release/press4_009291.html; “Japan imposes more sanctions on Russia, Belarus,” Japan Today (Mar. 8, 2022), available at https://japantoday.com/category/politics/update1-japan-imposes-more-sanctions-on-russia-belarus-over-ukraine-invasion; Ministry of Foreign Affairs of Japan, “Foreign Exchange and Foreign Trade Law Measures Concerning the Situation in Ukraine” (Mar. 1, 2022), available at https://www.mofa.go.jp/mofaj/press/release/press4_009282.html; “Japan freezes assets of 17 more Russian politicians, tycoons and families,” Japan Today (Mar. 15, 2022), available at https://japantoday.com/category/politics/Japan-freezes-assets-of-17-more-Russian-politicians-tycoons-and-families; “Japan adds Russia sanctions, U.S. envoy offers home to Ukrainians,” Reuters (Mar. 18, 2022), available at https://www.reuters.com/world/japan-slaps-new-sanctions-russian-defence-officials-arms-exporter-2022-03-18/; “Japan to freeze assets of additional 25 Russian individuals - foreign ministry,” Reuters (Mar. 24, 2022), available at https://www.reuters.com/world/europe/japan-freeze-assets-additional-25-russian-individuals-foreign-ministry-2022-03-25/?taid=623d3615a25f70000123e130&utm_campaign=trueAnthem:+Trending+Content&utm_medium=trueAnthem&utm_source=twitter; Ministry of Foreign Affairs of Japan, “Press Conference by Foreign Minister HAYASHI Yoshimasa” (Mar. 8, 2022), available at https://www.mofa.go.jp/press/kaiken/kaiken24e_000108.html; “Japan to expel 8 Russian officials, impose new sanctions,” ABC News (Apr. 8, 2022), available at https://abcnews.go.com/International/wireStory/japan-announces-expulsion-russian-diplomats-83955233; “Japan OKs asset freezes on Putin’s daughters, 396 other Russians,” Kyodo News (Apr. 12, 2022), available at https://english.kyodonews.net/news/2022/04/c3def6cb040f-urgent-japan-oks-asset-freezes-on-398-russians-incl-putins-daughters.html.

[35] “Japan adds Russia sanctions, U.S. envoy offers home to Ukrainians,” Reuters (Mar. 18, 2022), available at https://www.reuters.com/world/japan-slaps-new-sanctions-russian-defence-officials-arms-exporter-2022-03-18/; “Japan to freeze assets of additional 25 Russian individuals - foreign ministry,” Reuters (Mar. 24, 2022), available at https://www.reuters.com/world/europe/japan-freeze-assets-additional-25-russian-individuals-foreign-ministry-2022-03-25/?taid=623d3615a25f70000123e130&utm_campaign=trueAnthem:+Trending+Content&utm_medium=trueAnthem&utm_source=twitter; “Japan to expel 8 Russian officials, impose new sanctions,” ABC News (Apr. 8, 2022), available at https://abcnews.go.com/International/wireStory/japan-announces-expulsion-russian-diplomats-83955233.

[36] Ministry of Foreign Affairs of Japan, “Sanction Measures following Russia’s Recognition of the ‘Independence’ of the ‘Donetsk People’s Republic’ and the ‘Luhansk People’s Republic’ and the ratification of treaties with the two ‘Republics’” (Feb. 24, 2022), available at https://www.mofa.go.jp/press/release/press4e_003085.html.

[37] “Japan to expel 8 Russian officials, impose new sanctions,” ABC News (Apr. 8, 2022), available at https://abcnews.go.com/International/wireStory/japan-announces-expulsion-russian-diplomats-83955233; “Japan OKs asset freezes on Putin’s daughters, 396 other Russians,” Kyodo News (Apr. 12, 2022), available at https://english.kyodonews.net/news/2022/04/c3def6cb040f-urgent-japan-oks-asset-freezes-on-398-russians-incl-putins-daughters.html.

[38] “Japan parliament OKs revoking Russia’s ’most favored’ trade status,” ABS CBN News (Apr. 20, 2022), available at https://news.abs-cbn.com/business/04/20/22/japan-parliament-oks-revoking-russias-trade-privileges.

[39] “Japan imposes more sanctions on Russia, Belarus,” Japan Today (Mar. 8, 2022), available at https://japantoday.com/category/politics/update1-japan-imposes-more-sanctions-on-russia-belarus-over-ukraine-invasion; Ministry of Foreign Affairs of Japan, “Foreign Exchange and Foreign Trade Law Measures Concerning the Situation in Ukraine” (Mar. 3, 2022), available at https://www.mofa.go.jp/mofaj/press/release/press4_009291.html.

[40] Ministry of Foreign Affairs of Japan, “Sanction Measures following Russia’s Recognition of the ‘Independence’ of the ‘Donetsk People’s Republic’ and the ‘Luhansk People’s Republic’ and the ratification of treaties with the two ‘Republics’” (Feb. 24, 2022), available at https://www.mofa.go.jp/press/release/press4e_003085.html.

[41] Ministry of Foreign Affairs of Japan, “Sanction Measures following the launch of military actions by Russia in Ukraine (Statement by Foreign Minister HAYASHI Yoshimasa)” (Feb. 25, 2022), available at https://www.mofa.go.jp/press/release/press6e_000371.html; Ministry of Foreign Affairs of Japan, “Press Conference by Foreign Minister HAYASHI Yoshimasa” (Mar. 8, 2022), available at https://www.mofa.go.jp/press/kaiken/kaiken24e_000108.html.

[42] Ministry of Foreign Affairs of Japan, “Press Conference by Foreign Minister HAYASHI Yoshimasa” (Mar. 8, 2022), available at https://www.mofa.go.jp/press/kaiken/kaiken24e_000108.html.

[43] Ministry of Foreign Affairs of Japan, “Foreign Exchange and Foreign Trade Law Measures Concerning the Situation in Ukraine” (Mar. 1, 2022), available at https://www.mofa.go.jp/mofaj/press/release/press4_009282.html;“Japan freezes assets of 17 more Russian politicians, tycoons and families,” Japan Today (Mar. 15, 2022), available at https://japantoday.com/category/politics/Japan-freezes-assets-of-17-more-Russian-politicians-tycoons-and-families; “Japan to ban exports of nearly 300 items to Russia, Belarus,” Japan Today (Mar. 16, 2022), available at https://japantoday.com/category/politics/update1-japan-to-ban-exports-of-nearly-300-items-to-russia-belarus.

[44] “Japan to freeze assets of additional 25 Russian individuals - foreign ministry,” Reuters (Mar. 24, 2022), available at https://www.reuters.com/world/europe/japan-freeze-assets-additional-25-russian-individuals-foreign-ministry-2022-03-25/?taid=623d3615a25f70000123e130&utm_campaign=trueAnthem:+Trending+Content&utm_medium=trueAnthem&utm_source=twitter.

[45] “Japan to impose ban on Russia-bound exports of gold from April 5 - MOF,” The Financial Post (Mar. 29, 2022), available at https://financialpost.com/pmn/business-pmn/japan-to-impose-ban-on-russia-bound-exports-of-gold-from-april-5-mof.

[46] “Japan to phase out coal imports from Russia, add sanctions,” Nkkei Asia (Apr. 8, 2022), available at https://asia.nikkei.com/Politics/Ukraine-war/Japan-to-phase-out-coal-imports-from-Russia-add-sanctions.

[47] “Japan to phase out coal imports from Russia, add sanctions,” Nikkei Asia (Apr. 8, 2022), available at https://asia.nikkei.com/Politics/Ukraine-war/Japan-to-phase-out-coal-imports-from-Russia-add-sanctions.

[48]  “Japan parliament OKs revoking Russia’s ’most favored’ trade status,” ABS CBN News (Apr. 20, 2022), available at https://news.abs-cbn.com/business/04/20/22/japan-parliament-oks-revoking-russias-trade-privileges.

[49] “Japan to revise foreign exchange law to end crypto loophole for sanctions on Russia,” Reuters (Mar. 28, 2022), available at https://www.reuters.com/world/asia-pacific/japan-revise-foreign-exchange-law-end-crypto-loophole-sanctions-russia-2022-03-28/.

[50] New Zealand Foreign Affairs and Trade, “Details of Designations made under the Russia Sanctions Regulations 2022)” (Apr. 8, 2022), available at https://www.mfat.govt.nz/en/countries-and-regions/europe/ukraine/russian-invasion-of-ukraine/sanctions; Parliament of New Zealand, Russia Sanctions Regulations 2022, 2022/74, available at https://www.legislation.govt.nz/regulation/public/2022/0074/16.0/whole.html#LMS659631.

[51] New Zealand Foreign Affairs and Trade, “Details of Designations made under the Russia Sanctions Regulations 2022)” (Apr. 8, 2022), available at https://www.mfat.govt.nz/en/countries-and-regions/europe/ukraine/russian-invasion-of-ukraine/sanctions; Parliament of New Zealand, Russia Sanctions Regulations 2022, 2022/74, available at https://www.legislation.govt.nz/regulation/public/2022/0074/16.0/whole.html#LMS659631.

[52] New Zealand Foreign Affairs, “Russian banks targeted under latest round of sanctions” (Apr. 19, 2022), available at https://www.beehive.govt.nz/release/russian-banks-targeted-under-latest-round-sanctions#:~:text=%E2%80%9CAotearoa%20New%20Zealand%20is%20imposing,assets%2C%E2%80%9D%20Nanaia%20Mahuta%20said.

[53] New Zealand Foreign Affairs and Trade, “Details of Designations made under the Russia Sanctions Regulations 2022)” (Apr. 20, 2022), available at https://www.mfat.govt.nz/en/countries-and-regions/europe/ukraine/russian-invasion-of-ukraine/sanctions; Parliament of New Zealand, Russia Sanctions Regulations 2022, 2022/74, available at https://www.legislation.govt.nz/regulation/public/2022/0074/16.0/whole.html#LMS659631; New Zealand Foreign Affairs, “Russian banks targeted under latest round of sanctions” (Apr. 19, 2022), available at https://www.beehive.govt.nz/release/russian-banks-targeted-under-latest-round-sanctions#:~:text=%E2%80%9CAotearoa%20New%20Zealand%20is%20imposing,assets%2C%E2%80%9D%20Nanaia%20Mahuta%20said.

[54] New Zealand Foreign Affairs and Trade, “Details of Designations made under the Russia Sanctions Regulations 2022)” (Apr. 20, 2022), available at https://www.mfat.govt.nz/en/countries-and-regions/europe/ukraine/russian-invasion-of-ukraine/sanctions;

[55] “New Zealand, Which Lacks Own Sanctions Law, Joins Condemnation of Russia,” WSJ (Feb. 25, 2022), available at https://www.wsj.com/livecoverage/russia-ukraine-latest-news/card/geXTLJoJnJkrAJ5Djpz2; Parliament of New Zealand, Russia Sanctions Regulations 2022, 2022/74, available at https://www.legislation.govt.nz/regulation/public/2022/0074/16.0/whole.html#LMS659631.  

[56] Government of New Zealand, “New Zealand to apply trade sanctions in response to Russian atrocities” (Apr. 6, 2022), available at https://www.beehive.govt.nz/release/new-zealand-apply-trade-sanctions-response-russian-atrocities.

[57] Parliament of New Zealand, Russia Sanctions Regulations 2022, 2022/74, available at https://www.legislation.govt.nz/regulation/public/2022/0074/16.0/whole.html#LMS659631.

[58] Ministry of Foreign Affairs, “Sanctions against Russia incorporated into Norwegian law” (Mar. 18, 2022), available at https://www.regjeringen.no/en/aktuelt/russia_sanctions/id2904511/; Government of Norway, “New sanctions against Russia incorporated into Norwegian law” (Mar. 24, 2022), available at https://www.regjeringen.no/en/aktuelt/new_sanctions/id2905508/.

[59] MAS Notice SNR-N02 (Mar. 14, 2022), available at https://www.mas.gov.sg/-/media/MAS-Media-Library/regulation/anti-money-laundering/targeted-financial-sanctions/MAS-Notice-SNRN02-14-Mar-2022final.pdf?la=en&hash=8D8B7C6DB85B8FDE7D39827E28FD947EAFED2CB4.

[60] Ministry of Foreign Affairs Singapore, “Sanctions and Restrictions Against Russia in Response to its Invasion of Ukraine” (Mar. 5, 2022), available at https://www.mfa.gov.sg/Newsroom/Press-Statements-Transcripts-and-Photos/2022/03/20220305-sanctions; MAS Notice SNR-N01 (Mar. 14, 2022), available at https://www.mas.gov.sg/-/media/MAS-Media-Library/regulation/anti-money-laundering/targeted-financial-sanctions/MAS-Notice-SNRN01-14-Mar-2022final.pdf?la=en&hash=4B03AD1146B48D9C499268EC919285BE35634A9C.

[61] Ministry of Foreign Affairs Singapore, “Sanctions and Restrictions Against Russia in Response to its Invasion of Ukraine” (Mar. 5, 2022), available at https://www.mfa.gov.sg/Newsroom/Press-Statements-Transcripts-and-Photos/2022/03/20220305-sanctions; MAS Notice SNR-N01 (Mar. 14, 2022), available at https://www.mas.gov.sg/-/media/MAS-Media-Library/regulation/anti-money-laundering/targeted-financial-sanctions/MAS-Notice-SNRN01-14-Mar-2022final.pdf?la=en&hash=4B03AD1146B48D9C499268EC919285BE35634A9C.

[62] Ministry of Foreign Affairs, “Korean Government’s Decision on Additional Financial Sanctions against Russia” (Mar. 7, 202), available at https://www.mofa.go.kr/eng/brd/m_5676/view.do?seq=322012.

[63] Ministry of Foreign Affairs, “Korean Government’s Decision Regarding Situation in Ukraine” (Feb. 28, 2022), available at https://www.mofa.go.kr/eng/brd/m_5676/view.do?seq=322003&page=2.

[64] Ministry of Foreign Affairs, “MOFA Spokesperson’s Statement on Korean Government’s Decision on Export Control Measures on Belarus” (Mar. 6, 2022), available at https://www.mofa.go.kr/eng/brd/m_5676/view.do?seq=322011&page=1.

[65] Ministry of Foreign Affairs, “Korean Government’s Decision Regarding Situation in Ukraine” (Feb. 28, 2022), available at https://www.mofa.go.kr/eng/brd/m_5676/view.do?seq=322003&page=2.

[66] Federal Council of Switzerland, “Switzerland Adopts EU sanctions Against Russia” (Feb. 28, 2022), available at https://www.admin.ch/gov/en/start/documentation/media-releases.msg-id-87386.html; Federal Council of Switzerland, “Ukraine: Further trade and financial sanctions imposed against Russia” (Mar. 4, 2022), available at https://www.admin.ch/gov/en/start/documentation/media-releases.msg-id-87474.html; Federal Council of Switzerland, “Violations of international law in Ukraine: further individuals sanctioned” (Mar. 16, 2022), available at https://www.admin.ch/gov/en/start/documentation/media-releases.msg-id-87619.html; Ukraine: Adoption of further EU sanctions against Russia and Belarus (Apr. 13, 2022), available at https://www.admin.ch/gov/en/start/documentation/media-releases.msg-id-88028.html.

[67] Federal Council of Switzerland, “Switzerland Adopts EU sanctions Against Russia” (Feb. 28, 2022), available at https://www.admin.ch/gov/en/start/documentation/media-releases.msg-id-87386.html.

[68] Federal Council of Switzerland, “Ukraine: Adoption of further EU sanctions against Russia” (Mar. 18, 2022), available at https://www.admin.ch/gov/en/start/documentation/media-releases.msg-id-87677.html.

[69] Federal Council of Switzerland, “Ukraine: Adoption of further EU sanctions against Russia” (Mar. 18, 2022), available at https://www.admin.ch/gov/en/start/documentation/media-releases.msg-id-87677.html; Federal Council of Switzerland, “Ukraine: Implementation of further EU sanctions” (Mar. 25, 2022), available at https://www.admin.ch/gov/en/start/documentation/media-releases.msg-id-87747.html.

[70] Federal Council of Switzerland, “Ukraine: Federal Council tightens sanctions against Belarus” (Mar. 16, 2022), available at https://www.admin.ch/gov/en/start/documentation/media-releases.msg-id-87614.html.

[71] Ukraine: Adoption of further EU sanctions against Russia and Belarus (Apr. 13, 2022), available at https://www.admin.ch/gov/en/start/documentation/media-releases.msg-id-88028.html.

[72] Federal Council of Switzerland, “Switzerland Adopts EU sanctions Against Russia” (Feb. 28, 2022), available at https://www.admin.ch/gov/en/start/documentation/media-releases.msg-id-87386.html.

[73] Federal Council of Switzerland, “Ukraine: Adoption of further EU sanctions against Russia” (Mar. 18, 2022), available at https://www.admin.ch/gov/en/start/documentation/media-releases.msg-id-87677.html; Federal Council of Switzerland, “Ukraine: Implementation of further EU sanctions” (Mar. 25, 2022), available at https://www.admin.ch/gov/en/start/documentation/media-releases.msg-id-87747.html.

[74] Federal Council of Switzerland, “Ukraine: Adoption of further EU sanctions against Russia” (Mar. 18, 2022), available at https://www.admin.ch/gov/en/start/documentation/media-releases.msg-id-87677.html; Federal Council of Switzerland, “Ukraine: Implementation of further EU sanctions” (Mar. 25, 2022), available at https://www.admin.ch/gov/en/start/documentation/media-releases.msg-id-87747.html.

[75] Federal Council of Switzerland, “Ukraine: Implementation of further EU sanctions” (Mar. 25, 2022), available at https://www.admin.ch/gov/en/start/documentation/media-releases.msg-id-87747.html; Ukraine: Adoption of further EU sanctions against Russia and Belarus (Apr. 13, 2022), available at https://www.admin.ch/gov/en/start/documentation/media-releases.msg-id-88028.html.

[76] Federal Council of Switzerland, “Ukraine: Federal Council tightens sanctions against Belarus” (Mar. 16, 2022), available at https://www.admin.ch/gov/en/start/documentation/media-releases.msg-id-87614.html.

[77] Ukraine: Adoption of further EU sanctions against Russia and Belarus (Apr. 13, 2022), available at https://www.admin.ch/gov/en/start/documentation/media-releases.msg-id-88028.html.

[78] Federal Council of Switzerland, “Ukraine: Further trade and financial sanctions imposed against Russia” (Mar. 4, 2022), available at https://www.admin.ch/gov/en/start/documentation/media-releases.msg-id-87474.html.

[79] “Taiwan tightens Russia export curbs, details tech rules,” Reuters (Apr. 6, 2022), available at https://www.reuters.com/world/asia-pacific/taiwan-tightens-russia-export-curbs-details-tech-rules-2022-04-06/.

[80] “Taiwan steps up sanctions, bans select high-tech exports to Russia,” Focus Taiwan (Apr. 6, 2022), available at https://focustaiwan.tw/politics/202204060023.

[81] “Taiwan tightens Russia export curbs, details tech rules,” Reuters (Apr. 6, 2022), available at https://www.reuters.com/world/asia-pacific/taiwan-tightens-russia-export-curbs-details-tech-rules-2022-04-06/; “Taiwan steps up sanctions, bans select high-tech exports to Russia,” Focus Taiwan (Apr. 6, 2022), available at https://focustaiwan.tw/politics/202204060023.