Ukraine Crisis – EU Sanctions Update – ARCHIVE

Mayer Brown


May 12, 2022

  •  Hungary Demands Solutions to Russian Oil Import Issue: In an interview with Spanish newspaper El Pais on Thursday, Hungarian Foreign Minister Péter Szijjártó outlined the investments Hungary would need to undertake to wean itself off Russian oil, and hoped the EU could provide a solution. He estimated the country would need €500 and €550 million to update its refinery, and €200 million to update its Adriatic Sea pipeline. Hungary has opposed the EU’s proposed ban on imports of Russian oil, and this estimate is the closest Hungary has come to providing a price tag for its support of the package. (https://www.politico.eu/article/hungary-calls-on-eu-for-cash-ban-russian-oil-viktor-orban/).

  • Ten More European Companies Open Ruble Accounts at Gazprombank: Despite recent uncertainty as to the legality of President Putin’s rubles-for gas payment scheme, ten more European gas buyers have opened ruble-denominated accounts at Gazprombank for the purposes of making gas payments. In all, 20 companies have opened the accounts, with 14 others asking for paperwork to set them up. Sources at Gazprom indicate that only four customers to date have refused to pay for Russian gas in rubles. (https://www.bloomberg.com/news/articles/2022-05-12/ten-more-european-gas-buyers-open-ruble-accounts-for-payments).

  • Spain Identifies Russian Assets for Seizure: On Thursday, Spanish authorities announced that they had identified assets, including houses, companies and at least one luxury yacht, belonging to 15 Russian oligarchs on the EU sanctions list. Sources within Spanish law enforcement told Reuters that the information was handed over to authorities in April, and the government froze 12 funds and bank accounts, three luxury yachts, and 23 properties. The source identified 10 Spanish companies and 13 foreign ones with ties to sanctioned oligarchs. (https://www.reuters.com/world/europe/spain-finds-yacht-other-assets-15-sanctioned-russian-oligarchs-2022-05-12/).

  •  European Commission Unveils Plan to Export Ukrainian Grain: On Thursday, the European Commission announced a “solidarity lanes” plan to help export 20 million tons of grain out of Ukraine by the end of July. The measures include efforts to connect buyers to Ukrainian grain sellers, give priority to grain exports leaving Ukraine on EU infrastructure networks, and provide shipping equipment and storage for Ukrainian grain. (https://ec.europa.eu/commission/presscorner/detail/en/ip_22_3002).  


May 11, 2022

  • EU Plans to Help EU Countries Confiscate Frozen Assets: The European Commission is reported to prepare a proposal that would make sanctions violation or evasion an EU crime so as to provide Member States with a legal basis to confiscate frozen assets. The proposal is expected to be unveiled on May 25. The matter may be contentious for Member States, which have traditionally been reluctant to accept justice reforms that would need changes to their legal systems. (https://www.reuters.com/world/europe/eu-seeks-ease-rules-seizing-sanctioned-oligarchs-assets-2022-05-11/).


May 10, 2022

  • No Breakthrough on Russian Oil Ban in Talks Between Hungary & European Commission Presidents: Following her express trip to Hungary, European Commission President Ursula Von der Leyen did not return with an agreement from the Hungarian president to support to Russian oil ban as part of the new sanctions package. (https://www.politico.eu/article/von-der-leyen-to-travel-to-hungary-over-oil/).

  • European Commission Considers Indemnifying Hungary to Obtain Support for Oil Ban: As Hungary continues to oppose the proposed Russian oil ban in its current form (despite the European Commission’s proposal for a delayed phase-out period for Hungary, Slovakia and the Czech Republic), the European Commission is reportedly considering efforts to convince Hungary to sign up to the new sanctions package by offering it financial compensation to end its reliance on Russian fossil fuels. An announced videoconference between the Commission and regional players, which was due to discuss cooperation on oil infrastructure this morning, was postponed until further notice. It’s unclear whether a deal with Hungary can be reached before EU ambassadors meet again Wednesday morning. (https://www.politico.eu/article/eu-russian-oil-ban-orban-hungary-cash-sanctions/).

  • Lithuanian Parliament Names Russia a Sponsor of Terrorism: On Tuesday, the Lithuanian parliament passed a resolution declaring Russia’s invasion of Ukraine a “genocide” and labeling Russia as a “perpetrator of terrorism.” The resolution, which passed unanimously, recognized “the full-scale armed aggression — war — against Ukraine by the armed forces of the Russian Federation and its political and military leadership […] as genocide against the Ukrainian people.” (https://www.cnn.com/europe/live-news/russia-ukraine-war-news-05-10-22/h_87b1ee5432bc68c4d3ab7b360a3eed99).


May 09, 2022

  •  European Commission President Visits Hungary to Reach Deal on Oil Ban: President Von der Leyen is reported to have travelled to Budapest to discuss the ban on Russian oil with Hungarian President Viktor Orban. The trip is expected to yield a deal allowing for the formal green-light of the next sanctions package tomorrow. (https://www.politico.eu/article/von-der-leyen-to-travel-to-hungary-over-oil/).

  • EU Reported to Drop Plans to Ban Shipping of Russian Oil: On Monday, the Financial Times reported that, in light of opposition from Member States, and in particular Greece, the European Commission has dropped the proposal to prohibit the shipping of Russian oil as part of its next sanctions package, while prohibitions on insurance and financial services to Russian oil cargoes would be maintained. (https://www.ft.com/content/4b4ad184-1d88-4d51-92da-8e698ab3ec3c).

  • European Commission Considers Concessions to Win Support for New Sanctions Package:The European Commission is reportedly considering offering Eastern countries more money to upgrade oil infrastructure in a bid to convince them to support the new sanctions package, in addition to the phase-out until the end of 2024 agreed for Hungary and until mid-2024 for Slovakia and the Czech Republic. Cyprus is also reported to have concerns with a proposed ban on sale of properties to Russians. (https://www.reuters.com/world/europe/eu-considers-more-funds-eastern-states-bid-deal-russia-oil-ban-2022-05-09/).   


May 08, 2022

  • No Weekend Deal on Sanctions Package:According to Politico, talks on the EU’s sixth sanctions package broke down on Sunday without a deal. Negotiators are struggling to agree on the details of the EU’s proposed ban on Russian oil imports. Hungary, which has long been a vocal opponent of the ban, is reportedly seeking a “total opt-out” from the ban; the EU has proposed delayed compliance with the ban for Hungary and Slovakia until the end of 2024. Bulgaria is also displeased with the text, as it would like an extended phase-out period. Negotiators will return to the table on Monday or Tuesday, and were optimistic that an agreement could be reached by Tuesday. (https://www.politico.eu/article/eus-russian-oil-ban-stalls-as-hungary-holds-up-sanctions/).

  • G7 Promises to Ban Russian Oil Imports: After a call with G7 leaders and Ukrainian President Volodymyr Zelenskyy on Sunday, the G7 parties released a joint statement detailing their intended next steps to punish Russian aggression in Ukraine. In spite of the difficulties in passing an EU oil ban, the G7 partners announced their commitment to “phase out our dependency on Russian energy, including by phasing out or banning the import of Russian oil.” The group promised to work together to maintain global supply and price stability in energy markets. (https://www.whitehouse.gov/briefing-room/statements-releases/2022/05/08/g7-leaders-statement-2/).


May 06, 2022

  • EU Rewrites Oil Ban to Give Hungary, Slovakia and Czech Republic More Time: As Hungary, Slovakia and Czech Republic called for more time to phase out Russian oil, the European Commission has proposed a revised draft, which would provide for the possibility for these three countries to import Russian oil until the end of June 2024. Despite this proposal, no agreement has been reached yet on the sixth Russia sanctions package. (https://www.politico.eu/article/eu-re-writes-oil-ban-to-give-hungary-slovakia-and-czech-republic-more-time/).


May 05, 2022

  • Council President Calls for Confiscation of Sanctioned Russian Assets: In a Thursday interview with Interfax Ukraine, Charles Michel spoke in support of confiscating sanctioned assets to make Russia pay for damages to Ukraine, although he acknowledged that such seizures would entail significant legal issues across the different national legal systems of all 27 Member States. (https://www.politico.eu/article/michel-confiscate-sanctioned-assets-russia-oligarchs/).


May 04, 2022

  • European Commission President Announces New Sanctions Package: Speaking before the European Parliament, President Von der Leyen announced that the EU would impose a new sanctions package against Russia, including (i) additional asset freeze measures, (ii) de-SWIFTing of three banks, including Sberbank, (iii) ban on three Russian State-owned broadcasters, (iv) restrictions on the provision of services by accountants and consultants to Russian companies and (v) a complete import ban on Russian oil (including seaborne and pipeline, crude and refined), with imports phased out “within six months” for crude oil and “by the end of the year” for refined products. (https://ec.europa.eu/commission/presscorner/detail/en/speech_22_2785).

  • More Details on the New Sanctions Package: Politico reports that the three banks to be excluded from SWIFT would be Sberbank, Credit Bank of Moscow, and Russian Agricultural Bank. Rossiya RTR/RTR Planeta, Rossiya 24 and TV Centre International would be banned from broadcasting in the EU. Patriarch Kirill would be amongst the new asset freeze targets. In addition, Russians will be banned from buying homes and other property within the EU (https://www.politico.eu/article/eu-target-vladimir-putin-oil-bank-propaganda-new-russia-sanction-plan/).

  •  EC Proposal that Hungary and Slovakia Receive Special Treatment under Oil Ban: The European Commission is reported to propose that Hungary and Slovakia would be granted until the end of 2023 to stop their Russian oil imports. This exclusion would take the form of a derogation, whereby authorizations may be granted by the competent authorities of Hungary and Slovakia for contracts concluded before the new sanctions package enters into force. (https://www.politico.eu/article/hungary-and-slovakia-set-to-get-one-extra-year-to-kick-off-from-russian-oil/).

  • Slovakia Still Opposes to EU’s Current Sanctions Plan, While Hungary Expresses Reservations: Slovakia’s Energy Minister has announced his country will not be able to agree to the European Commission’s current proposal for an import ban on Russian oil, stating the proposal to give an extra year to adapt was not enough, as Slovakia expects at least three years is needed to transition off Russian oil. Hungary has also expressed reservations. (https://www.politico.eu/article/russian-oil-ban-slovakia-cant-accept-eus-current-sanctions-plan/).

  •  EU Amends Dual-Use Regulation to Withdraw Benefit of General Authorizations to Russia: The EU has amended certain of its general authorizations under its dual-use framework to remove Russia from authorized destinations. This brings the Dual-Use Regulation in line with EU sanctions that prohibit, subject to exemptions and derogations, the export of dual-use items to Russia (https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32022R0699&from=EN).

  • Maersk Loses Over $717m due to Exit From Russia in Q1: Shipping giant Maersk lost $717 million in the first quarter of 2022, as the company exited Russia following the Ukrainian invasion. According to a Bloomberg report, $627 million of the Russian losses were write-downs and $91 million were increases in operating costs. (https://www.arabnews.com/node/2075611/business-economy).

  • Italian Authorities Investigating Yacht Ownership: Italian authorities are investigating the ownership of the yacht Scheherazade as the boat prepares for departure from the Tuscan port of Marina di Carrara after sea tests. The yacht has been linked to Russian President Vladimir Putin, who is currently subject to sanctions in multiple jurisdictions, but true beneficial ownership is still under investigation. A spokeswoman for Italy’s financial police stated that, if the yacht left port, Italian authorities would not have any ability to stop it. (https://www.nytimes.com/2022/05/04/world/europe/russia-putin-superyacht-sanctions.html).


May 03, 2022

  • New Sanctions Package May Require Two Separate Meetings of EU Ambassadors: As the European Commission struggles to convince Member States to approve an import ban on Russian oil, in particular those with heavy dependency on Russian hydrocarbons, officials have been reported to expect that the agreement on a new sanctions package might take two separate meetings between European ambassadors, with the first one scheduled for Wednesday morning. (https://www.cnbc.com/2022/05/03/russia-sanctions-eu-nears-oil-embargo-hungary-and-slovakia-want-exemptions.html).

  • Italian PM Calls for End to EU Unanimity Rule on Foreign Policy Decisions: In a speech to the European Parliament, Mario Draghi said that the decision-making capacity to respond to Russia should be accelerated by using a “qualified majority” approach rather than the unanimity rule for the adoption by the EU of foreign policy decisions, including on sanctions (https://www.ft.com/content/17276897-970f-4451-85bd-7a685cec0894).

  • Lack of EU Sanctions on Russian Diamonds Draws Scrutiny: On Tuesday, Time published a profile of the Belgian diamond industry, noting that the EU has abstained from sanctioning Russian state-owned diamond company Alrosa while the US and UK have already imposed restrictions on the company. Belgian officials stated that a sanction on Russian diamonds would harm the EU more than it harms Russia, similar to arguments used in energy bans. (https://time.com/6172665/russia-diamonds-sanctions-belgium/).


May 02, 2022

  • EU Ambassadors to Meet on Wednesday to Discuss New Sanctions Package: The new package, expected to target Russian oil, Russian and Belarusian banks, and more individuals and companies, has been discussed by Commission officials and member state ambassadors one-on-one this weekend and is expected to be discussed on Wednesday, although a final agreement may not be reached at this meeting. (https://www.ft.com/content/c8eedb92-9512-4648-8146-d1450fcbd7e9).

  •  Italy in Favor of Allowing Energies Companies to Pay for Gas in Rubles, While Waiting for Clarifications: The Italian minister in charge of energy security has spoken in favor of allowing energy companies to pay in rubles for gas, while the legal framework and considerations for such payments are being considered. He stressed that energy companies should not be left in the dark and risk being accused of violating sanctions, while not paying in rubles. The EU Energy Commissioner has confirmed the European Commission would issue more detailed guidance on what energy companies can do within the framework of sanctions (https://www.politico.eu/article/italy-eu-energy-pay-russia-gas-rubles/).

  • World’s Largest Wind Turbine Manufacturer Cites Ukraine Conflict as a Reason for Q1 Losses: In its revenues report released on Monday, Danish wind turbine manufacturer Vestas said that revenues in the first quarter rose 27 percent to €2.5 billion, but it swung to an operating loss before special items of €329 million from a profit a year ago of €251 million. Even though the conflict in Ukraine is fueling demand for alternative energy sources, the conflict is also disrupting the supply chains the industry needs to construct turbines. Vestas also cited rising inflation as another challenge. (https://www.ft.com/content/91493287-e15e-4c2f-8994-a08583344623).

  •  French Utility Company Expands Investments in US LNG: On Monday, French state-backed utility Engie announced that it had signed a contract with Houston-based liquefied natural gas (“LNG”) company NextDecade. The company committed to buy 2.4 billion cubic meters a year of LNG for 15 years. Prior negotiations between the two companies fell apart in 2020 over environmental concerns, but the conflict in Ukraine has made investment in the US more attractive for European companies. (https://www.ft.com/content/920881a4-e72f-4c7e-89d3-587a5d34e0c1).

  • UEFA Bans Russian Teams, Cancels Russian Bid to Host Euros: On Monday, the Union of European Football Associations (“UEFA”) announced further restrictions on Russian participation in upcoming international events. The Russian women’s national team will no longer compete in the Women’s European Championship and qualification tournaments for the 2023 World Cup, and Russian club teams will no longer participate in the Champion’s League. The announcement also canceled Russia’s bid to host the Men’s Euros in 2028 and 2032. (https://news.sky.com/story/russian-bid-to-host-euros-in-2028-is-thrown-out-12604272).   


May 01, 2022

  •  Sanctioned Russian Gas Company in Poland Warns of Fire Risk: Novatek Green Energy, a Polish subsidiary of Russian gas company Novatek that is subject to Polish sanctions announced earlier this week, warned that 500 containers filled with liquefied natural gas, which are stuck on railroad tracks in Poland, could explode if they aren’t immediately moved to terminals. Weather conditions are making the situation more tenuous. (https://www.wsj.com/livecoverage/russia-ukraine-latest-news-2022-04-30).

  • Dutch Dockworkers Refuse to Unload Ship with Russian Diesel: On Saturday, unionized dock workers in Amsterdam refused to unload diesel from the tanker Sunny Liger, saying that the contents of the ship was helping to fund the war in Ukraine. The move comes after the ship was refused entry in Sweden and the port of Rotterdam for similar reasons, though its cargo is not currently subject to EU sanctions. (https://www.aljazeera.com/news/2022/4/30/dutch-dockers-refuse-to-unload-ship-with-russian-diesel-cargo).


April 29, 2022

  • European Commission Expected To Discuss 6th Package With Member States Over the Week End: the European Commission is reported to discuss informally proposals for a sixth sanctions package with the EU Member States over the week-end, including an oil embargo, sanctioning Sberbank and additional asset freeze measures (https://twitter.com/MarkerJParker/status/1520049704880508929).


April 28, 2022

  • European Commission Repeats that Complying with Rubles Payments for Gas Would Breach EU Sanctions: EU officials have been reported to repeat their warning that complying with the Russian decree requiring payments in rubles for gas would be a breach of EU sanctions, after several reports that gas distributors in Germany, Austria, Hungary and Slovakia had been planning to comply with that request. (https://www.ft.com/content/aa0d294b-0982-4f94-a327-a93300444083).

  • EU Member States Divided Over European Commission’s Guidance on Gas For Rubles Scheme: Member States are reported to have conflicting approaches as regards whether the Russian gas for rubles scheme can comply with EU sanctions. The European Commission takes the view that compliance with EU sanctions would be guaranteed only if firms make clear their obligations are complied with once a payment is made in Euros, and not after it is converted in Rubles. However, Denmark, Finland, Greece, Slovakia and Spain said more clarity was needed. Other countries have casted doubts as regards the European Commission’s interpretation. (https://www.reuters.com/world/europe/europe-struggles-clarity-russias-roubles-for-gas-scheme-2022-04-28/).

  • EU Energy Groups Ready to Meet Russian Terms for Gas Payments: Germany’s Uniper, Austria’s OMV and Italy’s Eni have all indicated that they were considering or ready to make payments for gas in accordance with Russian terms, after having considered solutions that would be compatible with EU sanctions, challenging in particular the lack of clarity from the European Commission’s guidance in that regard. (https://www.ft.com/content/5c4ecf3f-67c9-4ae6-b1a2-d70f2ef7ac05).


April 27, 2022

  • EU Takes Steps To Ensure Ukraine’s Duty-Free & Quota-Free Access to the EU Market: On April 27, the European Commission put forward a proposal to suspend for one year import duties on all Ukrainian exports to the European Union, as well as the suspension of all EU anti-dumping and safeguard measures on Ukrainian steel (https://ec.europa.eu/commission/presscorner/detail/en/ip_22_2671).

  • European Commission President Announces Immediate Response to Gazprom’s Decision to Stop Gas Deliveries to Poland and Bulgaria:The European Commission President delivered a statement vowing an immediate, united and coordinated response to Gazprom’s decision, including steps to mitigate the impact on European consumers and additional work to ensure sufficient gas supply and storage in the medium term. (https://ec.europa.eu/commission/presscorner/detail/en/statement_22_2685).

  • EU Considers Use of Sanctioned Assets to Aid Ukraine: Poland is currently leading advocacy efforts at the EU to use the proceeds from seized, sanctioned assets to aid Ukraine. EU officials note that legal authority for such sales would require careful consideration, but the idea is gaining traction in partner nations, like the US and Canada. (https://www.ft.com/content/91ffdd88-fa02-4ae2-931d-f47f042e9ed4).

  • Bulgaria Exploring Legal Challenge to Gas Shutoff: In a Wednesday interview with CNN, Bulgarian Energy Minister Alexander Nikolov said that the Bulgarian government is exporting legal options to challenge Gazprombank’s shutoff of Russian gas supplies to the country. He said “Bulgargaz, the state-owned entity, has executed the payment and then the money got returned from Gazprom. If we’re talking about a breach of the contract, then it is absolutely clear from a legal and legislation perspective who has breached the contract.” (https://www.cnn.com/europe/live-news/russia-ukraine-war-news-04-27-22/h_bc99d68e7e53749491cbf56a5a8f75e8).

  • Finland Prepared to Impose Harsher Sanctions on Russia: Speaking at a Veteran’s Day address on Wednesday, Finnish Prime Minister Sanna Marin said that the country was ready to impose tougher sanctions on Russia due to its invasion of Ukraine. She said, “We have sought to influence Russia’s actions by imposing severe sanctions on the country. We are also prepared to impose harsher sanctions. Our stance is clear: cooperation with Russia is not possible as long as the brutal attack continues.” (https://yle.fi/news/3-12420390). 

  • Total Takes Accounting Charge on its Natural Gas Reserves due to Russia Sanctions: French energy provider Total announced on Wednesday that it had taken a $4.1 billion accounting charge on the value of its natural gas reserves as a result of sanctions targeting Russia. Total is one of the few major European gas producers that has not committed to exiting Russian holdings following the invasion of Ukraine, saying a withdrawal would enrich Russia. The write-down indicates that it can no longer count on anticipated reserves located in Russia. (https://www.wsj.com/articles/frances-total-takes-4-1-billion-charge-related-to-russia-sanctions-11651093105?mod=livecoverage_web).  

April 26, 2022

  • Draft Russian Oil Ban Not Expected to Be Presented to EU Member States on Wednesday: While the European Commission initially planned to present its proposal for a ban on Russian oil imports early this week, it is reported that the proposal will not even be presented to the Member States for their meeting of Wednesday, noting that bilateral meetings between the European Commission and the Member States – aimed at crafting a compromise – have not taken place yet. (https://www.politico.eu/article/russia-ukraine-oil-sanctions-eu-waiting-game-vladimir-putin/).

  • Estonian President Calls for More Support to Help Ukraine: In an article for Politico, the president of Estonia emphasized that “[e]conomic sanctions must be strong and effective, without exception, and for immediate implementation”, stressed that “[w]e need an oil embargo, and we need it now” and reiterated Estonia’s proposal for an “escrow” to be set up for gas, whereas “[p]art of the payment for gas will be made directly to Russia, while the other part will be transferred to a separate account, frozen for Ukraine, which will be able to use it in the future to rebuild its destroyed nation.” (https://www.politico.eu/article/its-time-to-be-bolder-to-help-ukraine/).

  • German Energy Minister Predicts Independence from Russian Oil Within Days: During a visit to Poland, German Energy Minister Robert Habeck said “an [oil] embargo has become manageable for Germany,” since the country may be able to find replacements for Russian oil “within days.” This significantly speeds up Habeck’s previous predictions on German independence from Russian oil, which estimated independence by the end of the year. (https://www.reuters.com/business/energy/germany-aims-find-alternative-russian-oil-within-days-2022-04-26/).


April 25, 2022

  •  European Commission Prepares Sixth Sanctions Package: The sixth sanctions package being prepared by the European Commission is reported to include some form of ban on Russian oil and the exclusion of more Russian banks from SWIFT, while the Baltic countries continue to push for more measures against Russian disinformation. (https://www.politico.eu/article/eu-sanction-valdimir-putin-russia-ukraine/).

  • But No Proposal Expected Until Next Week: According to reports, the presentation and adoption of the sixth sanctions package is more likely to take place next week, despite a meeting of EU ambassadors being scheduled for Wednesday. (https://twitter.com/laurnorman/status/1518584302652567552).

  • EU to Launch Solar Strategy to Reduce Dependence on Russian Fossil Fuels: Speaking at the International Solar Alliance on Sunday, European Commission President Ursula Von Der Leyen said that the EU would be launching a new domestic solar strategy next month as part of its new REPowerEU initiative, to reduce European dependence on Russia. She stated, “For us, Europeans, it is a stark reminder that our dependency on Russian fossil fuels is not sustainable. Because how can you do business with someone, who openly threatens Europe and wages war against one of your closest neighbours?” (https://ec.europa.eu/commission/presscorner/detail/en/speech_22_2602).


April 22, 2022

  • European External Action Service and US Department of State Issue Joint Statement: The joint statement by the EEAS Secretary General and US Deputy Secretary of State stresses commends “the exceptional display of transatlantic unity and EU-U.S. coordination in response to Russia’s unprovoked military aggression against Ukraine, including on sanctions and export controls”, stressed the “importance of continued coordination on the provision of security assistance to Ukraine and the implementation and enforcement of sanctions targeting Russia and Belarus, together with other like-minded partners” and urged China not to circumvent or undermine sanctions against Russia. The pair added that China should not provide any form of support for Russia’s aggression against Ukraine, and reaffirmed that such support would have consequences for the US’ and EU’s relationships with China. (https://www.eeas.europa.eu/eeas/eu-us-consultations-between-eeas-secretary-general-stefano-sannino-and-united-states-deputy_en).

  • Commissioner for Trade Calls for Additional Sanctions Against Russia: Speaking at a conference in Washington, Commissioner Dombrovskis stressed that the EU should do everything possible to help Ukraine, including “more and tougher sanctions on Russia” (https://twitter.com/VDombrovskis/status/1517522475223076864).


April 21, 2022

  • EU Weighs Various Options for Russian Oil Ban: The European Commission is reported to fine-tune a phase-out of Russian oil imports to be presented to EU Member States next week. There are fears that the proposed mechanism will be watered down to win support from hesitant Member States, notably Germany, Hungary, Austria, the Czech Republic, Slovakia and Bulgaria which fear the economic consequences. The Russian oil ban is expected to differentiate between various grades of Russian oil and whether it is delivered by tanker or pipeline and to be subject to a transition period. (https://www.politico.eu/article/eu-closes-in-on-russian-oil-ban-vladimir-putin-ukraine/).

  • Austria Stopped Importing Russian Oil in March: On Thursday, representatives from Austrian gas company OMV told Russian news outlet TASS that Austria stopped importing and refining oil from Russia in March. Only 7.8 percent of Austrian oil comes from Russia per year, though the country is much more dependent on Russian natural gas. (https://tass.com/economy/1440957).

  • Crypto Exchange Binance to Limit Offerings in Russia Due to EU Sanctions: On Thursday, crypto exchange Binance announced that it was transitioning accounts with assets exceeding 10,000 euros in value to withdraw-only mode, as a result of recent EU sanctions that banned high-value transactions in digital assets. Sources familiar with the matter estimate that fewer than 50,000 users hold accounts with a value exceeding 10,000 euros, though Russia is one of Binance’s top five markets globally. (https://www.bloomberg.com/news/articles/2022-04-21/binance-set-to-curb-services-to-russia-users-after-eu-sanctions).


April 20, 2022

  •  European Commission Works to Cut Cost of Russia Oil Ban: The European Commission is reported to consider tools to persuade skeptical Member States to accept a ban on Russian oil, including prolonged wind-down periods or a gradual ban. While some Member States are pushing for additional measures (including a ban on nuclear fuel, disconnecting Sberbank and Gazprombank from SWIFT and additional media bans), no date has been set yet to propose a sixth sanctions package. (https://www.reuters.com/business/energy/eu-works-cut-cost-russia-oil-ban-win-over-sceptics-source-2022-04-20/).


April 19, 2022

  • France Supports Russian Oil Import Ban:Speaking to Europe 1 Radio on Tuesday, French Economy Minister Bruno Le Maire said that France is urging other EU countries to support a ban on oil imports from Russia, noting that oil has been President Putin’s “primary source of currency” for several years. While France supports the ban, Minister Le Maire stated that several “European partners” are still hesitant to impose such a ban. (https://www.politico.eu/article/france-bruno-le-maire-eu-prioritize-ban-russia-oil-gas/).

  • Greece Impounds Russian Oil Tanker as Part of EU Sanctions: On Tuesday, Greek authorities impounded the Russian oil tanker Pegas off the coast of the Greek island of Evia. Greek authorities stated that the seizure was due to EU sanctions on Russia; the bloc has banned Russian-flagged vessels from entering EU ports, with some exceptions. The vessel’s cargo has not been seized. The Russian Embassy in Athens is working with the Greek government on the seizure. (https://www.reuters.com/world/europe/greece-seizes-russian-tanker-part-eu-sanctions-2022-04-19/).


April 18, 2022

  • EU Eyeing Financial Sector Sanctions, Particularly on Sberbank: In a Sunday interview with Bild am Sonntag, European Commission President Ursula Von Der Leyen stated that, in the forthcoming sixth sanctions package, the bloc was “looking further at the banking sector, specifically Sberbank, which accounts for 37 percent of the Russian banking sector.” The EU has previously hesitated to sanction major Russian banks, as they are the main payment vehicles for oil and gas payments to Russia. In addition, President Von Der Leyen added that the EU was working on “developing smart mechanisms that will allow oil to be included in the next sanctions package.” (https://www.reuters.com/business/finance/new-eu-sanctions-russia-target-sberbank-commission-head-tells-paper-2022-04-16/).
  • Italy, Romania Close Ports to Russian Ships: On Saturday, Italy and Romania announced that Russian ships will no longer be allowed in either of their ports, starting on Sunday, April 17. Italy cited the recent expansion of EU sanctions as the reason for the ban. Romania’s ban has a carveout for humanitarian vessels and vessels transporting assistance to EU countries, and it also bans ships that have changed their registration from Russia to any other country since February 24, 2022. (https://www.ukrinform.net/rubric-ato/3459388-italy-romania-closing-ports-to-russian-ships.html).
  • Delays at Polish Border as EU Ban on Russian and Belarusian Freight Road Operators Enter into Force: On Saturday, the EU’s ban on Russian and Belarusian freight road operators working in the EU entered into force. The BBC reported wait times as long as 33 hours, with an estimated 12 hour wait for some vehicles as the ban entered into force on Sunday morning. It is unclear how the EU will treat Russian and Belarusian trucks in Polish territory as the deadline passes. (https://www.bbc.com/news/world-europe-61133439).


April 15, 2022

  • EU Announces Humanitarian Activity Exception to Sanctions: The EU announced exceptions to its sanctions regime for humanitarian activities. The exceptions will apply to certain asset freeze measures; the prohibition to export, sell, supply, transfer or export goods and technology listed in Annex II of Regulation (EU) 2022/263 to the non-government controlled areas of the Donetsk and Luhansk oblasts of Ukraine; the prohibition relating to the provision of technical assistance or brokering services and the provision of financing or financial assistance relating to Annex II of Regulation (EU) 2022/263 items; the prohibitions relating to the provision of technical assistance, or brokering, construction or engineering services directly relating to infrastructure in the specified territories in the sectors referred to in Article 4(1) [transport; telecommunications; energy; the prospecting, exploration and production of oil, gas and mineral resources] as defined on the basis of Annex II of Regulation (EU) 2022/263. The exceptions apply to specifically named humanitarian organizations, but organizations not named in the announcement can petition for a license for humanitarian activity. (https://www.consilium.europa.eu/en/press/press-releases/2022/04/13/eu-introduces-exceptions-to-restrictive-measures-to-facilitate-humanitarian-activities-in-ukraine/).


April 14, 2022

  • Brussels Warns EU Countries that Ruble Gas Payments May Breach Sanctions: The European Commission has been reported to have circulated a preliminary legal assessment according to which the payment system contemplated for the purchase of gas in rubles, whereby currencies are switched through accounts held by Gazprombank,risks breaching sanctions by granting Russia control over the timing and rate of foreign currency conversion, as well as by breaching sanctions against Gazprombank. (https://www.politico.eu/article/brussels-warns-eu-countries-that-ruble-gas-payments-may-breach-sanctions/).

  • Netherlands Instructs Energy Companies to Not Pay for Russian Gas in Rubles: On Thursday, the Dutch government instructed energy companies operating in its territory to refuse Russia’s new terms for purchasing gas, saying that it agreed with the European Commission’s interpretation of the policy that paying for gas through Russia’s Gazprombank scheme violates EU sanctions. The move may inspire other European countries to institute similar restrictions on Russian energy payments. (https://www.bloomberg.com/news/articles/2022-04-14/netherlands-tells-its-companies-not-to-pay-for-gas-in-rubles).


April 13, 2022


April 12, 2022


April 11, 2022

  • EU Foreign Affairs Ministers Meet to Discuss Sanctions: HR Borrell confirmed that Foreign Affairs Ministers had “continued discussing how to implement these sanctions to avoid any kind of loopholes” and will “continue discussing to see what else can be done. Nothing is off the table, including sanctions on oil and gas. But today, no decision was taken, [it was] just a general discussion analysing the figures”. HR Borrell also confirmed that the EU would first target oil, before gas, as it “is a heavy bill and easier to replace.” (https://www.eeas.europa.eu/eeas/foreign-affairs-council-remarks-high-representative-josep-borrell-press-conference-0_en).

  • EU Countries Remain at Loggerheads Over Russian Energy Ban: EU Member States are still reported to have diverging views with regard to a potential ban on imports of Russian energy, due to fears of exacerbating the surge in energy prices. While the European Commission is working on a proposal to restrict oil imports, either through a ban or other measures, new measures were only informally discussed at the meeting of Foreign Affairs Ministers on Monday. (https://www.ft.com/content/540807a8-0e3e-4843-9aee-25b65a724217). The absence of any specific timeline for the imposition of measures on Russian oil was also implicitly confirmed by HR Borrell, speaking before the Foreign Affairs Council meeting, who simply stated that “[s]anctions are always on the table. (…) the Ministers will discuss about what are the next steps.” (https://www.eeas.europa.eu/eeas/foreign-affairs-council-remarks-high-representative-josep-borrell-upon-arrival-1_en).

  • Sixth Sanctions Package Could Be Presented After Easter: Following the meeting of Foreign Affairs Ministers on Monday, the European Commission is reported to consider presenting a sixth sanctions package, including sanctions on Russian oil, after Easter. (https://twitter.com/RikardJozwiak/status/1513509251007799302).

  •  Swedish Company Ericsson Announces “Indefinite Suspension” of Russian Business:Swedish company Ericsson – which had already suspended deliveries to Russia – announced on Monday that they had suspended all business activities in Russia for an indefinite period of time, setting aside provisions for losses and placing local staff on paid leave. (https://www.ft.com/content/dc09be0f-fec1-4b17-b660-94ae6acf9950).

  • France-Based Société Générale to Sell Stake in Rosbank to Russian Oligarch: Société Générale is reported to consider the sale of its participation in Rosbank and its Russian insurance operations to a holding company owned by Vladimir Potanin. (https://www.ft.com/content/21b64f70-e71e-47d7-bf24-ad90dfa6a854).

  • EU Adds 21 Russian Airlines to the EU Air Safety List: The EU Air Safety List details airlines that are subject to an operating ban or operational restrictions within the EU because they do not meet international safety standards. 21 Russian airlines were added due to serious safety concerns linked to Russia’s forced re-registration of foreign-owned aircraft, knowingly allowing their operation without valid certificates of airworthiness. (https://ec.europa.eu/commission/presscorner/detail/en/ip_22_2389).

  • Austrian Federal Chancellor Meets with Putin:  on Monday, Federal Chancellor Nehammer met with Putin and conveyed the message that “sanctions against Russia will remain in place and will continue to be tightened as long as people continue to die in Ukraine” (https://twitter.com/samgadjones/status/1513525787818926083).

  • Chancellor Scholz Discusses Sanctions with President Zelenskyy: On Sunday, German Chancellor Olaf Scholz held a phone call with Ukrainian President Volodymyr Zelenskyy. According to President Zelenskyy’s account of the call, the two discussed “anti-Russian sanctions, defense and financial support for Ukraine.”Germany has been hesitant to impose restrictions on energy imports from Russia, while President Zelenskyy has vocally called for such restrictions in recent weeks. (https://twitter.com/ZelenskyyUa/status/1513097304861032450?s=20&t=r2xNQFDWtXsk3-Ksl1iWyQ).


April 9, 2022


April 8, 2022

  • EU Adopts 5th Sanctions Package: the EU has adopted its 5th sanctions package against Russia through a series of legal actions (Legal Texts:  https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=OJ:L:2022:110:TOC  and https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=OJ:L:2022:111:TOC).  These include the following: 

    o    Asset freeze measures against four Russian Banks (VTB Bank, Bank Otkritie, Novikombank, Sovcombank) as well as 18 entities and 217 individuals, including oligarchs, businesspeople, Kremlin officials, proponents of disinformation and information manipulation, as well as family members.

    Member States may, in their discretion, choose to authorize certain wind-down activities, by 9 October 2022 for: 

    (i) operations, contracts, or other agreements, including correspondent banking relations, concluded with the 4 sanctioned Russian banks before 8 April 2022; or,

    (ii) where necessary for the sale and transfer of rights in a legal person, entity or body established in the Union where those proprietary rights are directly or indirectly owned by a sanctioned person, provided the proceeds of such sale and transfer remain frozen.

    o    Additional financial measures including: 

    (i) Cryptocurrency Service Restrictions to prohibit the provision of crypto-asset wallet, account or custody services to Russian nationals, residents or entities, if the total value of crypto-assets per wallet, account or custody provider exceeds EUR 10,000.  This adds to existing financial sanctions prohibiting the acceptance of deposits from Russian nationals, residents or entities whose existing deposits exceed EUR 100,000 per credit institution.

    (ii) Restrictions on Trusts, prohibiting the provision of certain trust registration or management services to trusts having as a trustor or beneficiary:  (i) Russian nationals, residents, or entities; (ii) any entity owned or controlled by any individual or entity described in (i); or (iii) any individual or entity acting on behalf or at the direction of any of the foregoing.   The prohibitions also cover acting, or arranging for another person to act, as a trustee, nominee shareholder, director, secretary or a similar position, for such a trust.

    o   Additional Import Bans and Import-Related Technical, Financial and Other Service Prohibitions including:

    (i) Coal and Solid Fossil Fuel Restrictions which prohibit any purchase, import or transfer into the EU, directly or indirectly, of coal and other solid fossil fuels, as listed in Annex XXII of Regulation 833/2014, that are of Russian origin or otherwise exported from Russia  The prohibition extends to technical assistance, brokering or other services as well as the provision of manufacture, maintenance and use of the foregoing items directly or indirectly in relation to the import ban, as well as to related financing and financial assistance.   

    (ii) Other Significant Russian Imports, further expanding the import ban to include an expansive list of items which generate significant revenues for Russia, as set forth in Annex XXI of Regulation 833/2014, including but not limited to various chemical agents and compounds, cement, rubber products, wood, spirits, liquor, high-end seafood, glass products, aluminum plates, sheets and strip.

    As a result of the new ban on coal and solid fossil fuels imports, exceptions / authorizations that were available for trade control measures in relation to imports of coal or solid fossil fuels have been removed.

    o    Additional Export and Export-Related Technical, Financial and Other Service Prohibitions  including:   

    (i) Items Determined to Contribute to the Enhancement of Russian Industrial Capacities, as listed in Annex XXIII of Regulation 833/2014, which covers an extensive list of additional products including but not limited to certain machinery and mechanical appliances, rail, tractors, vehicles and vehicle parts, optical products, plants, mineral products, chemicals, tanning or dyeing extracts, lubricants, glues, photographic or cinematographic goods, plastics, rubber products, wood, pulp, paper, textiles and textiles articles, stones, plaster, ceramic, glass and glassware, and base metals.   The prohibition extends to technical assistance, brokering or other services as well as the provision of manufacture, maintenance and use of the foregoing items directly or indirectly in relation to the import ban, as well as to related financing and financial assistance.   

    (ii) Jet fuel and fuel additives, as listed in Annex XX of Regulation 833/2014;

    (iii) Arms Ban imposing a complete prohibition on exports and services related to arms and related materials of all types (i.e., removing the prior contract exception that applied based on the previous arms embargo enacted in 2014).

    (iv) Further Expansion of Existing Control Lists including:

    – Annex VII of Regulation 833/2014 has been extended to cover miscellaneous items, including quantum computing, advanced semiconductors, sensitive machinery, transportation and chemicals;

    – Annex X of Regulation 833/2014 has been extended to cover items suited for use in oil refiningand items suited for use in liquefaction of natural gas, as listed in Annex X of Regulation 833/2014 (which has also been amended to clarify that controls do not cover the full customs codes listed in that annex);

    – Annex XVIII of Regulation 833/2014 (luxury items) has been extended to cover certain optical articles and equipment of any value.

    These prohibitions are subject to exceptions and/or authorizations, including for winding down operations.

    o Restrictions on the transport sector including:

    (i) A ban on Russian ‘road transport undertakings’ (land freight companies), preventing them from transporting goods by road within the EU, including in transit;

    (ii)  A ban on access to EU ports for Russian-flagged vessels after April 16, 2022, including for vessels that have changed their Russian flag or registration after February 24, 2022.

    These bans are subject to a number of exceptions and/or authorizations.

    o    Public Funding and Contracting Restrictions including:

    (i) Public Procurement Prohibitions on awarding or continuing the execution of public procurement contracts to or with (i) Russian nationals and entities established in Russia, (ii) entities whose proprietary rights are more than 50% owned by them and (iii) individuals or entities acting on their behalf or at their direction (including subcontractors, suppliers or entities whose capacities are being relied on, where they account for more than 10 % of the contract value).

    This ban is subject to a number of authorizations, as well as a wind-down exception until October 10, 2022.

    (ii)  Public Financing and Financial Assistance Prohibitions on the provision to Russian entities with over 50% public ownership or public control of financing, financial assistance and benefits under any EU, Euratom or Member State programs (e.g., Horizon 2020, Horizon Europe, Euratom, Erasmus+), subject to certain exceptions.

    o    Expansion of Existing Reporting obligations to cover detected instances of breach, circumvention and attempts at breach or circumvention of the prohibitions set out in this Regulation through the use of crypto-assets.

    o    Clarifications on existing restrictions including

    (i) Amendments to the grounds for exemptions and authorizations in relation to prohibitions on dual-use items and advanced technology items as listed in Annex VII of Regulation 833/2014;

    (ii) Extension of prohibitions on the sale, supply, transfer or export to Russia or for use in Russia of EUR-denominated banknotes to all banknotes denominated in EU currencies;

    (iii) Extension of prohibitions on the sale of EUR-denominated transferable securities to Russian citizens, residents and entities to all transferable securities denominated in EU currencies.

    o    Additional Belarus RestrictionsThe 5th sanctions package also covers Belarus and provides for the following measures:

    (i)  A ban on Belarusian road transport undertakings, preventing them from transporting goods by road within the EU, including in transit;

    (ii)  Extension of prohibitions on the sale, supply, transfer or export to Belarus or for use in Belarus of EUR-denominated banknotes to all banknotes denominated in EU currencies;

    (iii)  Extension of prohibitions on the sale of EUR-denominated transferable securities to Russian citizens, residents and entities to all transferable securities denominated in EU currencies.

    Effective Dates.  The new asset freeze measures entered into force as from their publication in the Official Journal on April 8, 2022. Other measures enter into force on April 9, 2022.

    Press releases and Q&A: 




  • European Commission Announces That €30 Billion of Russian and Belarussian Assets Have Been Frozen: Following a meeting of the “Freeze and Seize Task Force” established to ensure coordination of the enforcement of EU sanctions against Russia and Belarus, the European Commission announced that €29.5 billion of Russian and Belarussian assets have been frozen, while about €196 billion of transactions have been blocked as reported by more than half of the Member States. (https://ec.europa.eu/commission/presscorner/detail/en/ip_22_2373).

  • EU Oil Embargo on Russia Expected “Sooner Rather than Later”: EU officials, including High Representative Borrell, have been reported to believe that the adoption of a ban on Russian oil import was “more of question of when, rather than if”, as political pressure for such a move is mounting. Some Member States are also considering pushing for nuclear fuel to be part of the sanctions regime, in addition to the controversial gas sanctions. (https://www.ft.com/content/fe2aee92-4a98-4158-9f4e-e5b5a38becbf).

  • But Russian Oil Embargo Will Not Be Tabled at EU Meeting on Monday: According to a senior EU official, there will be no formal proposal for a Russian oil embargo to be discussed by Member States at the meeting of EU foreign ministers scheduled for next Monday, due to divisions between Member States. (https://www.reuters.com/article/ukraine-crisis-eu-oil-idAFL5N2W63D9).

  • European, Parliament Calls for a Full Embargo on Russian Oil, Coal, Gas and Nuclear Fuel: In a resolution adopted on Thursday, the European Parliament called for additional punitive measures against Russia, including “an immediate full embargo on Russian imports of oil, coal, nuclear fuel and gas,” the exclusion of Russia from the G20 and other multilateral organizations, the exclusion of Russian banks from SWIFT, a ban on Russian vessels’ access to EU ports and road freight transport from and to Russia and Belarus and the seizure of all assets belonging to Russian officials or the oligarchs associated with Putin’s regime, their proxies and strawmen and those in Belarus linked to Lukashenka’s regime. (https://www.europarl.europa.eu/news/en/press-room/20220401IPR26524/meps-demand-full-embargo-on-russian-imports-of-oil-coal-nuclear-fuel-and-gas).

  • Von der Leyen States Payments for Gas in Rubles Violate EU Sanctions: In a Friday interview with CNN, European Commission President Ursula Von der Leyen said that any payments for Russian gas made in rubles would be a violation of EU sanctions law. The announcement comes after Hungarian President Viktor Orban stated a willingness to pay for Russian gas with rubles earlier this week. President Von der Leyen stated in the interview that the EU was in negotiations with Hungary on the issue of sanctions compliance. (https://www.cnn.com/europe/live-news/ukraine-russia-putin-news-04-08-22/h_fa7065e787fefaff368b02dc2150d472).


April 7, 2022

  • Member States Agree on 5th Sanctions Package With Adoption Expected Tomorrow: EU Member States have agreed to adopt a 5th sanctions package against Russia. This package is currently subject to a written procedure due to be concluded by tomorrow morning. New measures should be published after that in the Official Journal of the EU. The French Presidency of the Council confirmed the package includes (i) sanctions against oligarchs, Russian propaganda actors, members of the security and military apparatus and entities in the industrial and technological sector linked to the Russian aggression against Ukraine, (ii) asset freezes against several Russian banks, (iii) ban on coal imports from Russia, (iv) embargo on arms to Russia, (v) ban on exports to Russia, including high-ban on imports from Russia of raw and critical materials, (vii) ban on access to EU ports for ships flying the Russian flag and (viii) ban on Russian and Belarusian road transporters. (https://twitter.com/Europe2022FR/status/1512154182299619332).


April 6, 2022

  • EU to Extend Financial Sanctions on Russian High-Profile Executives: The EU is expected to extend the list of persons subject to asset freezes and travel bans to high-profile executives, including the chief of the e-commerce platform Ozon, the majority stakeholder in gold miner Polyrus, the chair of Sberbank, the director-general of Surgutneftegas and a top executive of Russia’s largest aluminum producer Rusal. Sanctions are also expected to target Putin’s daughters (https://www.ft.com/content/da05eabe-161a-43ee-a2a1-5e1a212583b4).

  • European Council President Expects Sanctions on Russian Oil and Gas in the Future: European Council President Charles Michel said he expects measures on Russian oil and  gas will be needed “sooner or later.” A decision on the issue will depend heavily on Germany’s position. The German Finance Minister indicated that cutting gas was not possible at the moment and that it will be necessary to differentiate between oil, coal and gas. (https://www.politico.eu/article/eu-move-ban-russia-oil-gas/).

  • European Council President Details New Sanctions Against Russia: European Council President Charles Michel addressed the European Parliament. President Michel praised a proposal from several Member of Parliaments that would grant asylum for Russian soldiers who disobey Russian orders. He mentioned that the EU was toughening its sanctions and stated his intent to target any attempt to circumvent sanctions. He said the EU will stop Russian vessels from entering EU ports and impose a ban on Russian and Belarussian road transport operators. The EU will impose a full transaction ban on more banks in order to further weaken Russia’s financial system, and will coordinate efforts with the G7. (https://www.consilium.europa.eu/en/press/press-releases/2022/04/06/report-by-president-charles-michel-to-the-european-parliament-plenary-session/).

  • Russia Still Has Friends in Italy: The no-show of certain politicians during Ukrainian President Volodymyr Zelenskyy’s address to the Italian Parliament in March underlines the close link between certain Italian politicians and Russia. Certain political figures voted against sending arms to Ukraine. Around 12 percent of Italians think the Russian invasion is justified, according to a recent poll. (https://www.politico.eu/article/italy-russia-love-affair-no-end/).

  • European Commission President Calls for Sanctions on Russian Oil: In an address to the European Parliament, Commission President Ursula von der Leyen called for sanctions on Russian oil and Russian oil revenues. President von der Leyen mentioned the possibility to diverting a share of oil revenues to an escrow account to limit the revenue Russia can make from fossil fuel sales. (https://ec.europa.eu/commission/presscorner/detail/en/speech_22_2321).  

  • Commission to Start Infringement Procedures Against Malta on Golden Passports: On Wednesday, the European Commission sent a reasoned opinion to Malta regarding its investor citizenship scheme. The Commission found that the granting of EU citizenship in return for pre-determined payments or investments, without any genuine link to the Member State concerned, is in breach of EU law. A similar procedure is being conducted against Cyprus and one may be triggered against Bulgaria. Malta now has to reply to the Commission, and if its answer is not satisfactory, the Commission may bring the case before the Court of Justice of the EU (https://ec.europa.eu/commission/presscorner/detail/en/ip_22_2068).


April 5, 2022

  • European Commission Announces Fifth Sanctions Package: In a press statement, the European Commission President announced that a new sanctions package had been submitted to the Member States, providing for (i) an import ban on Russian coal, (ii) a full transaction ban on 4 Russian banks, including VTB Bank, (iii) a ban on access to EU ports for Russian(-operated) vessels and a ban on Russian and Belarusian road transport operators, (iv) extended export control prohibitions targeting Russia, including on quantum computers, advanced semiconductors, sensitive machinery and transportation equipment, (v) new import bans on Russian wood, cement, seafood and liquor, (vi) a ban on participation of Russian companies in public procurement and exclusion of all financial support to Russian public bodies and (vii) new asset freeze measures (likely targeting oligarchs and their family members).

    This package is expected to be discussed by Member States on Wednesday and adopted either on Wednesday on Thursday.

    The European Commission President also stated that the EU continues to consider additional sanctions, including on oil imports and other measures such as taxes or specific payment channels such as an escrow account. (https://ec.europa.eu/commission/presscorner/detail/en/statement_22_2281).

  • Council of the EU Adopts Conclusions on Strategic Autonomy of the European Economic and Financial Sector: The conclusions notably highlight the importance of maintaining a well-functioning own EU sanctions regime, stressing “the importance of coordination between Member States regarding the implementation of sanctions, to ensure their effectiveness and maximize their impact,” commending the actions already taken to ensure uniform implementation and enforcement of EU sanctions, as well as support on-going actions to combat circumvention (including through crypto-assets) and emphasizing the importance of continued efforts to enforce strictly and uniformly all sanctions adopted. The conclusions also reiterate the EU’s opposition to extra-territorial sanctions and the importance of protecting EU operators from the effects thereof. (https://www.consilium.europa.eu/en/press/press-releases/2022/04/05/council-adopts-conclusions-on-strategic-autonomy-of-the-european-economic-and-financial-sector/).

  • Ukraine Calls on EU to Centralize Gas Purchases to Push Down Prices: Officials from Ukraine have called on the European Commission to nominate one authority to negotiate gas purchases at the EU level, in an effort to push down prices below current spot rates. The idea is to reduce profits for Gazprom, while allowing Ukraine to keep on earning transit fees (https://www.politico.eu/article/ukraine-eu-play-rough-russia-gas-prices/).


April 4, 2022

  • European Commission Issues Notice to Economic Operators, Importers & Exporters on Circumvention: In a notice, the European Commission invited EU economic operators to exercise caution vis-à-vis sanctions in light of risks of circumvention through exports to third countries and imports from third-countries. Economic operators are invited to implement due diligence measures and informed that customs authorities may carry out more strict controls to ensure sanctions are complied with. (https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv%3AOJ.CI.2022.145.01.0001.01.ENG&toc=OJ%3AC%3A2022%3A145I%3ATOC)

  • German Finance Minister Balks at Blanket Energy Ban: Speaking to the press before meetings in Brussels, German Finance Minister Christian Lindner stated, “It is clear we must end as quickly as possible all economic ties to Russia. Gas cannot be substituted in the short term.” He added that a blanket ban on Russian energy imports would hurt EU member states more than it hurts Russia, and urged colleagues to consider bans on oil, coal, or gas, which could be replaced at varying speeds. (https://www.reuters.com/world/europe/eu-must-end-all-economic-ties-russia-fast-possible-lindner-2022-04-04/).

  • Poland Considering Sanctions on United Russia Party Members: Polish Prime Minister Mateusz Morawiecki announced on Monday that he was asking the EU to consider sanctions against all members of the United Russia political party. United Russia is the largest political party in Russia and counts over 2 million people as members. (https://tass.com/world/1431925).


April 3, 2022

  •  EU Announces New Sanctions in Response to Bucha: In Sunday tweets, European Commissioner Ursula Von Der Leyen and European Council President Charles Michel both stated that new EU restrictions would be coming as a result of accounts of Russian soldiers committing atrocities against civilians in Bucha, Ukraine. Commissioner Von Der Leyen said, “Perpetrators of war crimes will be held accountable,” and President Michel said, “Further EU sanctions & support are on their way.” Politico confirmed that EU ministers have agreed to “speed through and tighten” further Russian sanctions. (https://www.politico.eu/article/ukraine-russia-civilian-executions-war-massacre/).

  • Latvia Says Baltic States Are No Longer Importing Russian Gas: In a Sunday Radio interview, Uldis Bariss, CEO of Conexus Baltic Grid,  Latvia’s natural gas storage operator, stated that the Baltic states Estonia, Latvia, and Lithuania had all stopped importing Russian natural gas, beginning on April 1. The statement expands on Lithuania’s announcement yesterday, where Lithuanian President Gitanas Nauseda called on the rest of Europe to join Lithuania in the effort. (https://www.aljazeera.com/amp/news/2022/4/3/baltic-states-stop-russian-gas-imports-over-ukraine-invasion).


April 2, 2022

  • Lithuania Suspends Purchases of Russian Gas: In a Saturday statement, Lithuanian President Gitanas Nauseda announced that Lithuania would no longer accept Russian gas, saying that all natural gas coming into the country will enter through the Klaipeda port. He added, “If we can do it, the rest of Europe can do it too.” Lithuania has not suspended transit of Russian natural gas to the Kaliningrad exclave, despite the day’s announcement. (https://www.reuters.com/business/energy/lithuania-ceasing-all-russian-gas-imports-domestic-needs-2022-04-02/).


April 1, 2022

  • EU Calls on China to Support Efforts to Stop War in China: The European External Action Service issued a press release on Friday on the EU-China summit. In the statement, the EU underlined the shared responsibility of EU and China as global actors to work for peace and stability. It called on China to support efforts to bring about an immediate end to the war in Ukraine, consistent with China’s role in the world as a permanent member of the UN Security Council, and noted the country’s uniquely close relations with Russia. The statement also mentions that any attempts to circumvent sanctions or to aid Russia by other means must be stopped. (https://www.consilium.europa.eu/en/press/press-releases/2022/04/01/eu-china-summit-restoring-peace-and-stability-in-ukraine-is-a-shared-responsibility/).


March 31, 2022

  • Estonian Prime Minister Calls on EU to Capture Part of the Energy Payments to Russia: Reiterating calls from earlier in the week, Estonian Prime Minister Kaja Kallas called on the EU to set up an escrow account to capture part of the payments for Moscow’s oil and gas and use it to rebuild Ukraine. The Prime Minister said the idea would be discussed among EU leaders on Thursday evening, although several member states were still assessing how this could be implemented. (https://euobserver.com/world/154587).

  • German Economy Minister Discusses Sanctions Impact: In a Thursday interview with public broadcaster ZDF, German Economy Minister Robert Habeck stated that Germany “will be poorer” due to Russia’s invasion of Ukraine and the accompanying sanctions programs. However, he said “I believe that we are ready to pay this price which is small enough compared to the sufferings in Ukraine.” (https://www.cnn.com/2022/03/31/business/germany-economy-war/index.html).

  • EU and US Oppose Linking Ukraine Peace Talks to Sanctions Relief for Russia: US and EU officials underlined that only a full ceasefire, troop withdrawal and return of captured territory to Ukraine would be enough to trigger discussions over lifting sanctions on Russia’s economy.(https://www.ft.com/content/a3c13f6d-3924-4abd-aa00-b29f1d65e0cf).


March 30, 2022

  • Commissioner McGuiness’ Statement on EU-US Dialogue on Sanctions: EU Commissioner for Financial Stability, Financial Services, and the Capital Markets Union Mairead McGuinness, who is responsible for sanctions, released a statement on the EU-US sanctions dialogue on Wednesday. In the announcement, she stressed the need to ensure “effective and full implementation of sanctions across jurisdictions” as a priority and the importance of cooperation with the US and other partners (https://ec.europa.eu/commission/presscorner/detail/en/SPEECH_22_2166).

  • Ukraine Minister of Foreign Affairs Discussed 5th Sanctions Package With HR Borrell: Dmytro Kuleba, Ukraine’s Minister of Foreign Affairs, discussed with High Representative Josep Borrell the “need to elevate sanctions pressure” through a 5th package of sanctions that should come as soon as possible and be as tough as possible.” (https://twitter.com/DmytroKuleba/status/1509144517663936519).

  • EU First-Tier Court Rejects RT France’s Request for Interim Measures to Suspend Sanctions:The President of the EU General Court rejected France’s request for interim measures to suspend sanctions against Russia, as urgency had not been established. However, the procedure on merits of the claim will be an accelerated one. (https://curia.europa.eu/jcms/upload/docs/application/pdf/2022-03/cp220054fr.pdf).

  • Ukraine Pushes for Import Ban on Russian Diamonds: Ukrainian President Volodymyr Zelenskyy is scheduled to speak to the Belgian parliament tomorrow; he is expected to push Belgium to ban imports of Russian rough diamonds, like the US has already done. Belgium and other key players in the diamonds sector are instead advocating for a multilateral ban before the EU takes any action on the issue in order to avoid diversion of Russian diamonds to other centers in India and the UAE. (https://www.politico.eu/article/diamond-trade-puts-belgium-in-antwerp-tough-spot-in-front-of-ukraine-zelenskyy/).


March 29, 2022

  • EU to Press China on Sanctions Circumvention: Ahead of Friday’s EU-China summit, Bloomberg is reporting that EU representatives will press Beijing to not sell arms to Russia or circumvent sanctions imposed on Russia. China rejected speculation that it was assisting Russia, adding that continued pressure may damage diplomatic relations with a key trading partner. (https://www.bloomberg.com/news/newsletters/2022-03-29/eu-to-press-china-on-russia-sanctions).

  • Poland to Ban Russian Coal Imports: On Tuesday, Polish government spokesman Piotr Mueller announced that the country was banning the import of Russian coal for national security reasons. Poland imports one fifth of its coal from Russia. The country has urged the EU to ban the import of oil and gas from Russia. (https://www.politico.eu/article/poland-to-ban-russian-coal-imports/).  


March 28, 2022

  • EBRD to Close Offices in Moscow, Minsk: On Monday, the European Bank for Reconstruction and Development (“EBRD”) announced that it is in the process of closing its Resident Offices in Moscow, Russia and Minsk, Belarus. Its statement on the matter said that the closure “is the inevitable outcome of the actions taken by the Russian Federation with the help of Belarus.” (https://www.ebrd.com/news/2022/ebrd-to-close-its-offices-in-moscow-and-minsk-.html).


March 25, 2022

  • European Council Issues Conclusions on Russian Military Aggression Against Ukraine Following Two-Day Meeting: Following itsmeeting of 24-25 March 2022, the European Council issued a statement reiterating inter aliathat the EU “remains ready to close loopholes and target actual and possible circumvention as well as to move quickly with further coordinated robust sanctions on Russia and Belarus to effectively thwart Russian abilities to continue the aggression”. The European Council also calls on all countries to align with those sanctions and warns that “[a]ny y attempts to circumvent sanctions or to aid Russia by other means must be stopped” (https://www.consilium.europa.eu/media/55082/2022-03-2425-euco-conclusions-en.pdf).

  • German Guidance Not Fully Consistent with European Commission Guidance: German authorities have published their own FAQs on Russia sanctions. In some cases, responses provided are in opposition with those provided by the European Commission. For instance, Germany considers there is no need to aggregated ownership of sanctioned parties, unless there are concrete indications that several EU-listed companies are acting together in exercising the shareholder rights. (https://www.bmwi.de/Redaktion/DE/FAQ/Sanktionen-Russland/faq-russland-sanktionen.html).

  • Poland, Slovenia and the Czech Republic Issue 10-Point Plan to Support Ukraine: The three countries are advocating inter alia for cutting off all Russian banks from SWIFT, blocking Russian ships from EU ports, blocking road transport in and out of Russia, imposing sanctions not only on oligarchs but on the entire business environment, suspending visas for Russian citizens, imposing sanctions on all members of Putin’s party, placing a total ban on export to Russia of technologies that can be used for war and excluding Russia from all international organizations. (https://www.politico.eu/article/poland-10-point-plan-save-ukraine/).

  • EU Member States Reported to Struggle With the Freezing and Seizing of Assets of Sanctioned Parties: Member States are reported to face challenges, which differ from one Member State to another, with only a small fraction of funds of sanctioned parties being actually frozen. Inconsistencies in enforcement of EU sanctions between the different Member States is also noted. The difference between freezing and seizing assets is also highlighted as a key issue, since seizures generally require specific and separate legal proceedings under the laws of each Member States   (https://www.reuters.com/world/europe/freeze-seize-eu-struggles-target-oligarchs-assets-2022-03-24/).

  • European Commission and US Issue Joint Statement on European Energy Security: In a joint statement, the European Commission and the United States committed to reducing Europe’s dependency on Russian energy, by setting up a task force on energy security with the aim of reinforcing US-EU cooperation, including through – amongst other actions – the US striving to ensure additional LNG volumes for the EU market of at least 15 bcm in 2022 with expected increases going forward. (https://ec.europa.eu/commission/presscorner/detail/en/statement_22_2041).


March 24, 2022

  • G7 Leaders Issue Statement Calling for Full Implementation of Sanctions and Warning of More Sanctions To Come: Following, the G7 leaders’ meeting in Brussels on March 24, 2022, Leaders issued a statement underlining their resolve to fully implement sanctions already imposed, coordinate with other governments on adopting similar measures, and refrain from undermining the sanctions adopted. G7 leaders also called for the full implementation of sanctions and coordinated responses to evasive measures. Finally, they stressed that they “stand ready to apply additional measures as required, continuing to act in unity.” (https://www.consilium.europa.eu/en/press/press-releases/2022/03/24/g7-leaders-statement-brussels-24-march-2022/).
  • NATO Members Warn China Against Helping Russia: NATO Leaders have reportedly raised concerns with regard to China undermining actions taken against Russia, including sanctions. Following their meeting of March 24, they issued a statement calling on China “to uphold the international order including the principles of sovereignty and territorial integrity, as enshrined in the UN Charter, to abstain from supporting Russia’s war effort in any way, and to refrain from any action that helps Russia circumvent sanctions.” (https://www.nato.int/cps/en/natohq/official_texts_193719.htm?selectedLocale=en).
  • HR Borrell Confirms European Council Summit Will Discuss Sanctions: In press remarks before the summit of the EU heads of state, High Representative Borrell confirmed that leaders were expected to discuss additional sanctions against Russia, although cautioning that “the Summit does not take concrete decisions and only provides political guidance for the technical bodies, and for the Foreign Affairs Ministers to decide in concrete terms.” He nonetheless expects the European Union Council to provide guidance on how to continue increasing the sanctions – personal sanctions and sectoral sanctions. (https://eeas.europa.eu/headquarters/headquarters-homepage/113429/european-council-remarks-high-representative-josep-borrell-upon-arrival_en).

  • While Other Member States Continue To Oppose Russian Energy Import Ban: Belgian PM Alexander de Croo was quoted saying that a full embargo on Russian energy would have a “devastating impact” on the European economy and that the EU was “not going to impose sanctions that weaken [it] unnecessarily.” (https://twitter.com/RosieBirchard/status/1507014863150727172).


March 23, 2022

  • EU Updates FAQ on Russia Sanctions: On March 23, 2022, the European Commission made substantial additions to its FAQ on Russia sanctions, including with regard to the scope of asset freeze measures, prohibitions on deposits, the application of sanctions to the insurance sector, the scope of the sanctions on access to the SWIFT network.

The new clarifications notably confirm that ownership or control by sanctioned parties have to be aggregated for the purposes of determining whether a non-designated entity is “owned” or “controlled” by a sanctioned party and therefore presumed to be subject to asset freeze measures.


  • Upcoming EU Member States Discussions on Sanctions to Focus on Circumvention, But New Sanctions Not Excluded:In his invitation letter to the members of the European Council ahead of their meeting on March 24 and 25 2022, President Charles Michel indicated that EU Member States “must now ensure that these sanctions are not circumvented”, while leaving the door open for more sanctions: “[w]e stand ready to move quickly on further coordinated sanctions”.

President Charles Michel had expressed a similar position earlier today in its report to the European Parliament plenary session: “[w]e are implementing these sanctions and working to close the loopholes that provide an escape for Russia, and we are prepared to do more, to starve Putin’s war machine”.



  • German Chancellor Warns About Economic Risks Linked to Energy Ban: Speaking to the Bundestag, German Chancellor Olaf Scholz stated that an immediate ban on Russian energy imports would trigger economic recession across Europe, warning that sanctions should not hit European countries harder than the Russian leadership. Germany’s repeated oppositions to a ban on Russian energy imports make it unlikely that EU Member States will reach an agreement in that regard within this week.


  • Credit Agricole, BNP Paribas Leave Russia:Major French bank Credit Agricole announced on Wednesday that it had suspended all services in Russia. It previously had suspended new financing for Russian companies. BNP Paribas also announced that it would no longer process transactions for clients in Russia after March 31. It also had suspended new financing for Russian companies prior to the announcement. (https://www.cnn.com/2022/03/23/investing/french-banks-russia/index.html).


March 22, 2022


March 21, 2022


March 20, 2022

  • France Seizes Russian Assets: In a Sunday interview, French Minister of the Economy and Finance Bruno Le Maire announced that the country had frozen 22 billion Euros of Russian Central Bank assets held in Russia, along with 150 million Euros in funds held by Russian individuals in French enterprises. The Minister also announced that the country had seized property worth “half a billion Euro” owned by around 30 Russians, including two yachts. (https://tass.com/economy/1424731).   


March 18, 2022


March 17, 2022

  • European Commission Issues Guidance Note on Russia Sanctions Export Controls: On March 17, the European Commission published a guidance note regarding the scope of controls under Russia sanctions applicable to dual-use items and advance technology items. The guidance note provides useful clarifications and recommendations regarding the scope and application of these controls.(https://trade.ec.europa.eu/doclib/docs/2022/march/tradoc_160079.pdf).


March 16, 2022

  • EU Member States Do Not Rule Out 5th Sanctions Package But Focus Should Be On Closing Loopholes:While there are still divisions between Member States on whether or not additional sanctions should be imposed against Russia, including the divisive issue of an energy ban, the European Commission is reported to prepare the groundwork for a fifth sanctions package. Nevertheless, no specific “trigger” appears to have been agreed as to when and if this fifth sanctions package should be adopted. At the moment, the focus of the majority of Member States seems to concern the necessity to close loopholes to ensure the effectiveness of already adopted sanctions.



March 15, 2022

  • EU Imposes New Sanctions Against Russia: The fourth package of sanctions targeting Russia has been adopted today and consist of:

    o   Asset freeze measures on 15 individuals, including oligarchs and media personalities, and 9 entities in the military and defense sectors.

    o   Restrictions on the energy sector, defined as covering, with the exception of civil nuclear-related activities:

    (i) the exploration, production, distribution within Russia or mining of crude oil, natural gas or solid fossil fuels, the refining of fuels, the liquefaction of natural gas or regasification;

    (ii) the manufacture or distribution within Russia of solid fossil fuel products, refined petroleum products or gas; or

    (iii) the construction of facilities or installation of equipment for, or the provision of services, equipment or technology for, activities related to power generation or electricity production.

    Restrictions on the energy sector consist in:

    (i) Limited grounds for authorizations for exports and services related to dual-use items and high-technology items (as listed in Annex VII of Regulation 833/2014), where intended for the energy sector;

    (ii) Prohibition on investments in entities (inside or outside Russia) operating in the energy sector in Russia (including prohibitions on acquisition of participations in legal persons, on the granting of financing, on the creation of joint ventures and on the provision of related investment services).

    o   Prohibition on exports and services related to items suited for oil exploration / production purposes (as listed in Annex II of Regulation 833/2014, which, previously, were subject to an authorization requirement and only prohibited in relation to specific oil projects).

    o   Prohibition on exports of luxury goods (as listed in Annex XVIII of Regulation 833/2014), where their value exceed EUR 300 per item (except if otherwise provided in Annex XVIII).

    o   Prohibition on imports, purchase and transport of, as well as services related to certain iron and steel products originating in or exported from Russia (as listed in Annex XVII of Regulation 833/2014, modelled on the EU safeguard measures on iron and steel products).

    o   Prohibition on engaging in any transactions with entities listed in Annex XIX of Regulation 833/2014 (i.e., OPK OBORONPROM, United Aircraft Corporation, Uralvagonzavod, Rosneft, Transneft, Gazprom Neft, Almaz-Antey, Kamaz, Rostec, JSC PO Sevmash, Sovcomflot and United Shipbuilding Corporation), the entities outside the EU they own for more than 50% and any entity, inside or outside the EU, acting on their behalf or at their direction.

    o   Extension of the list of individuals and entities for which specific (limited) authorization requirements apply in relation to exports and services related to dual-use items and high-technology items (as listed in Annex VII of Regulation 833/2014).

    o   Prohibition, as of April 15, 2022, on the provision of credit rating services or access to any subscription services in relation to credit rating activities. 

    The legal texts are available at:


    See also the European Commission’s press release and FAQ:



    See also the Council’s press release:


  • 40 WTO Members, Including All EU Member States Issue Joint Statement At the WTO: in a communication published on 15 March 2022, Albania, Australia, Canada, the EU Member States, Iceland, Japan, South Korea, Moldova, Montenegro, New Zealand, North Macedonia, Norway, the UK and the US issued a joint statement at the WTO condemning Russia’s military assault on Ukraine and emphasizing that they will take any actions considered necessary, including “actions to suspend concessions or other obligations with respect to the Russian Federation, such as the suspension of the most-favoured-nation treatment to products and services of the Russian Federation”. The WTO members also consider that Belarus’ accession process should be suspended in light of Belarus’ material support to the actions of Russia.



March 14, 2022

  • EU Agrees on Fourth Sanctions Package: EU member states have agreed to a fourth package of sanctions against Russia. Though text of the legislation is not yet public, it is reported to include a revocation of Russia’s most-favored-nation trading status, a ban on Russian steel and iron imports, an export ban on luxury goods to Russia, an addition of 14 oligarchs to the list of sanctioned Russian billionaires, and a suspension of Russia’s membership in multilateral banks. (https://www.reuters.com/world/europe/eu-member-states-press-ahead-with-new-package-sanctions-against-russia-2022-03-14/).

  • Additional Russian Oligarchs and Media Personalities To Be Subject To Asset Freeze Measures:while legal texts are not published yet, some names of asset freeze targets have been leaked, including R. Abramovich (owner of Chelsea FC); G. Khan (shareholder of Alfa Group); A. Kuzmichev (shareholder of Alfa Group); V. Rashnikov (owner of MMK); V. Rashevsky (CEO of EuroChem); A. Ryumin (head of Rosseti PJSC); S. Kerimov (owner of Nafta Moscow); A. Gasparyan, A. Sheynin and K. Ernst (media personalities); along with entities in the defense and military sectors, including Zelenodolsk Shipyard.(https://www.politico.eu/article/eu-sanctions-chelsea-owner-roman-abramovich-oligarch-russia/).


March 13, 2022

  • EU Ambassadors Meet to Finalize New Sanctions Package Sunday, Expected to Adopt Text Monday:On Sunday, EU ambassadors met to discuss new sanctions; text for the measure is expected to be announced on Monday. The measures are reported to include sanctions on 15 new oligarchs, including Chelsea Football Club owner Roman Abramovich; sanctions on Russian state-owned enterprises not yet listed; a rating ban on Russian banks; an import ban on Russian steel and iron products; a ban on new investment in the Russian energy sector; and an export ban on luxury goods to Russia. (https://www.ft.com/content/e4ebb442-bbe9-442d-bb29-e490c7c20ae6).


March 12, 2022

  • Germany Aims to be Independent of Russian Oil, Coal This Year: In an interview on Saturday, German Economy and Finance Minister Robert Habeck stated Germany “will be independent of Russian coal by the autumn and nearly independent of Russian oil by the end of the year.” However, he stated that cutting off imports of Russian gas will be more difficult, since the country imports more than half of its gas from Russia. (https://www.barrons.com/amp/news/germany-aims-to-be-nearly-free-of-russia-oil-this-year-01647088507).


March 11, 2022


March 10, 2022


March 09, 2022

  • EU Sanctions Against Russia Transposed Against Belarus: on March 9, 2022, the EU also imposed additional sanctions against Belarus, which replicate existing sanctions against Russia, namely:

    o   Clarification that restrictions on access to capital cover “transferable securities” in the form of crypto-assets and of the “common understanding” that loans and credits can be provided by any means, including crypto assets;

    o   Clarification of the “common understanding” that asset freeze measures on “funds” and “economic resources” cover crypto-assets;

    o   Clarification that anti-circumvention provisions apply to all restrictions set out in Regulation 759/2006;

    o   Prohibition on the provision of specialized financial messaging services for three Belarusian banks (Belagroprombank, Bank Dabrabyt and Development Bank of the Republic of Belarus) and the Belarusian entities that they own for more than 50%;

    o   Prohibition on transactions related to the management of reserves, as well as of assets of the Central Bank of Belarus, including transactions with any entity acting on its behalf or at its direction;

    o   Prohibition, as of 12 April 2022, of the listing or provision of services on EU trading venues for transferable securities of any Belarusian entity with over 50% public ownership;

    o   Prohibition on the provision of public financing or financial assistance for trade with, or investment in, Belarus;

    o   Prohibition on deposits by Belarusian nationals, residents or entities, if the total value of their deposits exceeds EUR 100 000 per credit institution;

    o   Prohibition for Union central securities depositories from providing certain services for transferable securities issued after 12 April 2022 to any Belarusian citizen, resident or entity;

    o   Reporting requirements on credit institutions in relation to deposits exceeding EUR 100 000 held by Belarusian citizens, residents and entities, as well as Belarusian golden passport or golden visa holders;

    o   Prohibition on the sale of EUR denominated transferable securities issued after 12 April 2022 (or units in collective investments undertakings providing exposure to such securities) to any Belarusian citizen, resident or entity;

    o   Prohibition on the sale, supply, transfer or export of EUR denominated banknotes to Belarus or for use in Belarus;

    o   Confirmation that controls on items listed in Annex VII of Regulation 759/2006 do not apply to non-controlled items containing or more controlled components, subject to rules on circumvention.

    Legal texts:


    Press releases:




March 08, 2022



March 07, 2022


March 06, 2022


March 04, 2022


March 03, 2022

  • EU Leaders Consider New Sanctions Package: At a meeting of the EU Political and Security Committee, diplomats discussed new possible sanctions on Russia. These measures could target oligarch’s families, trust funds, and property. Further restrictions on SWIFT were discussed, the proposal received some pushback, with some insisting on waiting for the initial SWIFT bans to go into force 10 days from now before implementing new ones. Debate remained preliminary, but a new sanctions package could be put on the table as early as Friday. (https://www.politico.eu/article/eu-next-possible-russia-targets-ports-oligarch-families-trust-funds/).


March 02, 2022

  • Fourth Sanctions Package Against Russia Adopted: the legal texts finalizing the additional sanctions agreed by the EU Member States on February 27, 2022 have been adopted and target access to SWIFT, the Russian Direct Investment Fund, euro denominated banknotes and Russian State-owned media.

In detail, these measures consist of:

o  Prohibitions on the provision of specialized financial messaging services against seven Russian banks (Bank Otkritie, Novikombank, Promsvyazbank, Bank Rossiya, Sovcombank, VEB and VTB Bank) and the Russian entities that they own for more than 50%;

o  Prohibitions on the sale, supply, transfer or export of euro denominated banknotes to Russia;

o  Prohibitions on investment, participation or contribution to projects co-financed by the Russian Direct Investment Fund;

o  Prohibition on broadcasting of certain Russian State-owned media (RT and Sputnik) and suspension of broadcasting licenses, authorization, transmission and distribution arrangements.

o  Reinforced cooperation between the United States and the European Union on the effectiveness and consistent application of export control measures.

The legal texts are available at:



Press releases are available at:



  • New Sanctions Against Belarus Adopted: while Member States had also agreed on February 27, 2022 to ramp up the existing sanctions against Belarus, the legal texts have also been adopted today and provide for far-reaching restrictions

    New sanctions against Belarus include:

o  Asset freeze measures against certain Belarusian military officers;

o  Prohibitions on export and services (technical assistance, brokering services, other services, financing and financial assistance) related to:

        1. Dual-use items, regardless of end-use or end-user (previously, prohibitions applied only in relation to military use or military end-user and specifically designated entities);
        2. Goods and technology which might contribute to Belarus’s military and technological enhancement, or to the development of its defense and security sector;
        3. A wide list of machineries, covering most of chapter 84 of the EU’s tariff nomenclature;

These new restrictions are subject to various exceptions or authorizations, including for wind-down.

o  Prohibition on import, transport and services (technical assistance, brokering services, financing and financial assistance) related to:

      1. Wood products, namely all products falling under chapter 44 of the EU’s tariff nomenclature;
      2. Cement products, namely all products falling under headings 2523 and 6810 of the EU’s tariff nomenclature;
      3. Iron and steel products, namely all products falling under chapters 72 and 73 of the EU’s tariff nomenclature;
      4. Rubber products, namely all products falling under heading 4011 of the EU’s tariff nomenclature;

These new restrictions are subject to wind-down exceptions.

o  Extension of existing controls:

      1. Restrictions on exports of goods used for the production or manufacturing of tobacco products have been extended to related technical assistance, brokering services, financing and financial assistance;
      2. Restrictions on imports of potash have been extended to related technical assistance, brokering services, financing and financial assistance;
      3. The scope of potash products subject to restrictions has been extended to cover all potash products under sub-heading 3104 20 of the EU’s tariff nomenclature, regardless of potassium content;
      4. Restrictions on imports of “petroleum and gaseous hydrocarbon products” have been extended to cover “mineral products”, now covering various types of oil covered by heading 2707 of the EU’s tariff nomenclature;

o  Removal of prior contract exceptions for restrictions on (i) tobacco products, (ii) potash, (iii) mineral products, (iv) access to capital and (v) insurance / re-insurance.

o  Reinforced cooperation between “partner countries” and the European Union on the effectiveness and consistent application of export control measures.


March 01, 2022


February 28, 2022

  • Third Sanctions Package Partially Enters Into Force: the following restrictive measures were adopted and immediately entered into force following their publication in the Official Journal:

o  Asset freeze measures against 26 Russian oligarchs, politicians, journalists, media personalities and military officials, as well as one entity: SOGAZ;

o  Travel ban measures against the individuals that have been designated as subject to asset freeze measures;

o  Restrictions on Russian aircraft landing in, taking off from or overflying the territory of the EU; and

o  Restrictions on transactions related to the management of reserves as well as of assets of the Central Bank of Russia.

  • Additional Sanctions Expected Shortly:

o  For Russia: restrictions targeting access to SWIFT for selected Russian banks; restrictions on the issuance of golden passports and ban on certain Russian State-owned media in the EU;

o  For Belarus: asset freeze measures and export control restrictions on mineral fuels, tobacco, wood and timber, cement, iron and steel, dual-use items.

  • While these sanctions have been politically endorsed, the legal texts have not been adopted yet.


February 27, 2022

  • EU Announces Further Measures Targeting the Air Transport and Media Sectors to Respond to the Russian Invasion of Ukraine: Following the announcement on February 26, 2022 of new restrictions targeting access to SWIFT, the Russian Central Bank, golden passport issuance and of the participation in transatlantic sanctions coordination, European Commission President Von der Leyen confirmed that the EU would also:

o Ban on EU airspace, by prohibiting Russian-owned, -registered or -controlled aircraft from landing in, taking or off or overflying the EU;

o Ban on Russian State-owned media in the EU, including Russia Today, Sputnik and their subsidiaries;

In the same address, referring to the joint announcement of February 26, the European President Commission indicated that:

o The Central Bank of Russia would be subject to an asset freeze;

o Russian oligarchs would be made subject to asset freeze measures.


  • EU Also Announces Further Measures Targeting Belarus, As Complicit in the Attack Against Ukraine: In the same address, the European Commission President announced that a new package of sanctions against Belarus would be adopted, including:

o Export control restrictions on mineral fuels, tobacco, wood and timber, cement, iron and steel, dual-use items;

o Asset freeze measures against “those Belarusians helping the Russian war effort”.

  • Political Endorsements of New Sanctions Packages February 28, 2022: In the evening of February 28, 2022, High Representative Borrell convened a meeting of EU Foreign Affairs Ministers to provide the political endorsement for the new sanctions packages against Russia and Belarus. He confirmed that the measures discussed above were approved by EU Member States, although details have not been circulated yet. Finalization of the legal texts and formal approval for adoption and publication in the Official Journal is expected “in the following hours”. High Representative Borrell confirmed that “everything needs to be done before tomorrow morning”.



February 26, 2022

  • EU Announces Same SWIFT, Central Bank, and Passport Restrictions as the US: The European Union released an identical press statement on further efforts to sanction Russia, including selective removal of Russian banks from SWIFT, Russian Central Bank restrictions, passport restriction, and transatlantic coordination. (https://ec.europa.eu/commission/presscorner/detail/en/statement_22_1423).

o    The Press and Information Office of the Federal Government of Germany stated that restrictions on access to SWIFT will apply to “all Russian banks that are already sanctioned by the international community, and, if necessary, other Russian banks.” (https://www.bundesregierung.de/breg-de/aktuelles/verbuendete-schliessen-russische-banken-aus-swift-aus-2008220).


February 25, 2022

  • The second sanctions package, in response to the invasion of Ukraine by Russian troops, was published and entered into force on February 25, 2022. Legal texts are available in the Official Journal of the EU at:


    The package includes new sanctions and export controls providing for:

1. Additional asset freeze and travel ban measures against Russian and Belarusian politicians and officials.  Putin and Lavrov included, although not subject to travel ban measures.  

2. New Export Controls and Restrictions on Related Services (technical assistance, brokering services, other services, financing or financial assistance) to or for use in Russia, targeting:

(i) Dual-use items,

(ii) Goods and technology which might contribute to Russia’s military and technological enhancement, or the development of the defense and security sector (“Strategic Items”),

(iii) Goods and technology suited for use in oil refining, and

(iv) Goods and technology suited for use in aviation or the space industry.

Of note, exceptions or authorization schemes are foreseen to allow for the winding-down of operations based on existing contracts.

Furthermore, specific exceptions and authorizations are also foreseen for restrictions on dual-use items and Strategic Items, including an exception mechanism akin to general licenses and authorizations for exports or services for the exclusive use of Russian entities owned or controlled by EU or US entities.

3. A definition of “financing or financial assistance”, clarifying that this involves a disbursement or commitment to disburse its own funds or economic resources by the relevant provider.

4. Special authorization requirements for the export of and the provision of services related to dual-use items and Strategic Items to 64 State-owned entities in the military and defense sectors, whereby such exports and services can only be authorized based on specific grounds, reminiscing of the US BIS Entity List.

5. Restrictions on specific services related to goods and technology suited for use in aviation or the space industry, including:

(i) insurance and reinsurance; and

(ii) overhaul, repair, inspection, replacement, modification or defect rectification of an aircraft or component, with the exception of pre-flight inspection.

6. Restrictions on public financing or financial assistance for trade with or investment in Russia, subject to limited exceptions.

7. Extension of restrictions on access to capital to four State-owned and private banks, as well as eight State-owned companies in the aerospace and defence, automotive, military, infrastructure, shipping and shipbuilding sectors.

These restrictions target Alfa Bank, Bank Otkritie, Bank Rossiya, Promsvyazbank, Almaz-Antey, Kamaz, Novorossiysk Commercial Sea Port, Rostec, Russian Railways, JSC PO Sevmash, Sovcomflot and United Shipbuilding Corporation. They also extend to certain entities which they own for more than 50% or which act on their behalf or at their direction.

These restrictions affect transferable securities / money-market instruments issued after April 12, 2022 and loans / credits granted after February 26, 2022.

8. Existing restrictions on access to capital, as applicable to Sberbank, VTB Bank, Gazprombank, VEB, Rosselkhozbank, OPK Oboronprom, United Aircraft Corporation, Uralvagonzavod, Rosneft, Transneft and Gazprom Neft, were reinforced.

9. Restrictions on the listing and provision of services on EU-registered or -recognised trading venues for transferable securities of Russian entities with over 50% public ownership as of April 12, 2022.

10. Restrictions on financial inflows and investments from Russia to the EU, targeting:

(i) A prohibition on deposits by Russian nationals, residents and entities exceeding 100 000 EUR per credit institution, coupled with specific reporting requirements for credit institutions (covering also “golden passports” or “golden visas” holders);

(ii) A prohibition for EU central securities depositories from providing certain services for transferable securities issued after April 12, 2022 to any Russian national, resident or entity;

(iii) A prohibition on the selling of euro denominated transferable securities issued after April 12, 2022 or units in collective investment undertakings providing exposure to such securities to any Russian national, resident or entity.

11. Restrictions on visa policies through the partial suspension of the application of the EU-Russia Agreement on the facilitation of the issuance of visas.

  • EU to Sanction Putin, Lavrov: In a Friday press conference, EU High Representative for Foreign Affairs Josep Borrell confirmed that the EU was moving to sanction Russian President Vladimir Putin and Russian Foreign Minister Sergei Lavrov. The pair maynot be subject to a travel ban in an attempt to keep diplomatic channels open. (https://www.ft.com/content/5e7282fc-4ea0-482d-a81a-8abb52228472).


February 24, 2022

  • Second Sanctions Package Announced: The adoption of a second sanctions package has been announced by the European Commission’s president in the early hours of the day:


    The package was announced to (i) “target strategic sectors of the Russian economy by blocking their access to technologies and markets that are key for Russia” and (ii) “freeze Russian assets in the European Union and stop the access of Russian banks to European financial markets

  • Initial Sanctions Package Adopted: The European Council adopted conclusions on Russia’s unprovoked and unjustified military aggression against Ukraine in the evening of February 22, 2024 (https://www.consilium.europa.eu/en/press/press-releases/2022/02/24/european-council-conclusions-24-february-2022/)

    These lay out, in general terms, the scope of this second sanctions package: “[t]hese sanctions cover the financial sector, the energy and transport sectors, dual-use goods, as well as export control and export financing, visa policy, additional listings of Russian individuals and new listing criteria”.

    Although the precise scope of this second sanctions package has not been disclosed, measures reported as under consideration include:

(i) additional asset freeze measures;

(ii) new listing criteria;

(iii) restriction on new listings on EU stock exchanges for certain State-owned entities;

(iv) extension of restrictions on access to capital to certain banks and state-owned enterprises, notably in the aerospace, defense, shipping and shipbuilding sectors;

(v) restrictions on export and services related to:

– dual-use goods,

– strategic goods for the military sector and advanced technologies (including electronics, sensors, telecommunications, marine applications and lasers),

– aircraft and parts, and

– equipment needed to upgrade Russian oil refineries;

(vi) restrictions on new large deposits by Russian nationals in EU financial institutions; and

(vi) restrictions on visa-free travel for Russian diplomatic passports.

  • The legal texts of this second sanctions package are expected to be finalized and formally adopted on February 25, 2022.

  • The European Council’s conclusions of February 24, 2022 confirm that a new sanctions package against Belarus should be prepared, to be adopted at a later date.

February 23, 2022

EU Sanctions Published – EU sanctions published just before midnight CET (February 23, 2020):  https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=OJ:L:2022:042I:FULL&from=FR 

See also  – https://www.consilium.europa.eu/en/policies/sanctions/ukraine-crisis/

  • The EU sanctions package includes:

o    Sanctions against over 375 individuals and entities, notably including Bank Rossiya, Promsvyazbank and VEB.RF, several banking executives, high-ranking public officials and businesspersons

o    Restrictions on non-government controlled areas of Donetsk and Luhansk

o    Restrictions on the ability of the Russian government to access capital and financial markets and services

  • Notably, the EU has provided a basis for Member State authorization to allow release of frozen funds/economic resources “necessary for the termination” by 24 August 2022 of contracts, operations, contracts or other agreements, including correspondent banking relations, that were in place before 23 February 2022
  • Also of note, several members of the management of VTB have been designated, including

(i) Dmitriy Yuryevich GRIGORENKO, Chairman of the Supervisory Council of the VTB Bank;

(ii) Maxim Gennadyevich RESHETNIKOV, member of the Supervisory Council of the VTB Bank

(iii) Denis Aleksandrovich BORTNIKOV, Deputy President and Chairman of VTB Bank Management Board; and

(iv) Andrei Leonidovich KOSTIN, President of the VTB Bank Management Board.

The implications this may have in terms of whether VTB Bank might be considered as “controlled” by sanctioned parties would need to be further considered.

  • Restrictions affecting the EU-Ukraine Association Agreement, while not formally part of the sanctions package, the European Commission has published a notice to importers regarding imports of products  into the Union under the EU-Ukraine Association Agreement from the non-government controlled areas of the Donetsk and Lugansk oblasts of Ukraine (here). In accordance with this notice, goods produced in or exported from the non-government controlled areas of the Donetsk and Lugansk oblasts of Ukraine can no longer benefit from preferential (i.e., duty-free) access to the EU market under the terms of the EU-Ukraine Association Agreement.

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