Ukraine Crisis – Other Notable Developments – Sanctions Update – ARCHIVE

Mayer Brown


May 12, 2022

  • Chinese Diplomat:  Sanctions Against Russia Will Only Increase “Food and Fuel Crisis”:  Speaking at a Thursday UN Security Council Meeting, Deputy Permanent Representative of China to the UN Dai Bing said, “Sanctions will not ensure peace, they will only accelerate the spread of the food and fuel crisis. As a result, children around the world will pay the highest price for this.” He called for Russia and Ukraine to cease hostilities and seek a diplomatic solution. (https://tass.com/world/1450267).


May 11, 2022

  • Russian Companies Seek Partnerships with Small Indian Enterprises: Reuters reported on Wednesday that Russian companies are increasing engagement with small Indian businesses for items like produce and medical devices, as sanctions regimes around the world limit areas where Russia can source products. Larger multinational corporations with offices in India are so far refusing to work with Russian counterparts due to sanctions regimes, but smaller companies with a reduced international footprint are more amenable to the transactions. (https://www.reuters.com/business/russian-importers-seek-deals-with-indias-smaller-firms-sidestep-sanctions-2022-05-11/).


May 10, 2022

  • Japan Announces New Sanctions on Russia:On Tuesday, the Japanese Ministry of Finance announced new asset freezes on 141 individuals in Russia and the Donetsk and Luhansk people’s republics. The sanctioned parties include Russian Prime Minister Mikhail Mishustin, oligarch Vladimir Bogdanov, and family members of oligarch Gennady Timshenko. In addition, the Ministry prohibited exports of Japanese goods to 71 organizations, including scientific research institutions. Finally, the restrictions introduce a ban on the export of “cutting edge goods” to Russia. (https://www.mof.go.jp/policy/international_policy/gaitame_kawase/gaitame/economic_sanctions/gaitamehou_shisantouketsu_20220510.html).


May 09, 2022

  • Japan to End Imports of Russian Oil: On Monday, Japanese Prime Minister Fumio Kishida announced that Japan would phase out and eventually ban the import of Russian oil, in line with G7 commitments. He said, “Japan relies on imports for most of its energy resources, so this is a very difficult decision, but right now the unity of the G7 is more important than anything else. We have decided to take the step of banning imports of Russian oil in principle.” Prime Minister Kishida did not propose a timeline for ending Russian oil imports. He added that the proposed ban would only apply to Russian oil, since only oil was mentioned in the G7 statement, but was open to further curbing exports of other energy products, like LNG, if the G7 called for it. (https://www.wsj.com/livecoverage/russia-ukraine-latest-news-2022-05-07/card/japan-plans-to-ban-the-import-of-russian-oil-znTOlaNoHhzKlRV4kfbO?mod=livecoverage_web).

  • Brazil Becomes Russian Fertilizer Export Destination: The New York Times reported on Monday that Brazil has become a popular destination for exports of Russian fertilizer, noting that, while sanctions have complicated financial transactions involving fertilizer, allowing these transactions to occur will blunt the impact of food price increases in the future. (https://www.nytimes.com/2022/05/08/world/americas/brazil-russian-fertilizer-sanctions.html).


May 08, 2022

  • Trudeau Announces New Sanctions During Visit to Kyiv: On Saturday, Canadian Prime Minister Justin Trudeau made a previously unannounced visit to Kyiv, where he met with Ukrainian President Volodymyr Zelenskyy. During a joint appearance with President Zelenskyy, Prime Minister Trudeau announced expanded Canadian military assistance to Ukraine, and that the country was imposing sanctions on an additional 40 Russian individuals and 5 Russian entities. He described the newly sanctioned parties as “oligarchs and close associates of the regime in the defense sector, all of them complicit in Putin’s war.” (https://www.reuters.com/world/europe/canadas-trudeau-announces-new-weapons-ukraine-visit-kyiv-2022-05-08/).

  • Taiwan Expands Sanctions Program to Belarus:On Friday, the Taiwanese Bureau of Foreign Trade announced that it would expand its export restrictions on technology goods currently in force on Russia to Belarus, as well. Taiwanese parties seeking to export technology products to Belarus will need to seek a license from the Ministry before the transaction. The Ministry noted that other jurisdictions, like the US and EU, have already imposed sanctions on Belarus. (https://www.trade.gov.tw/Pages/Detail.aspx?nodeID=4599&pid=742121).


May 06, 2022

  • Chinese Tech Companies Getting Out of Russia: Chinese technology companies, including Lenovo and Xiaomi Corp, are restricting their exports to Russia as scrutiny from countries like the US intensifies, according to a Wall Street Journal report on Friday. Consumer drone giant SZ DJI Technology Co even announced its suspension of exports to Russia. Chinese government trade data has supported these reports, with exports of laptops to Russia declining by 40 percent and exports of telecom base stations to Russia declining 98 percent between February and March. (https://www.wsj.com/articles/chinese-tech-giants-quietly-stop-doing-business-with-russia-11651845795?mod=hp_lead_pos4).


May 05, 2022

  • India Increases Imports of Russian Oil: The New York Times published an analysis of the Indian energy market on Thursday, highlighting that the country has increased imports of Russian gas from 300,000 barrels a day in March to 700,000 barrels a day in April. On average, India imported 33,000 barrels of oil a day from Russia in 2021. The increase in imports is largely due to low prices for Russian crude oil. The report notes that the US has refrained thus far from imposing restrictions on India due to its increase in Russian energy consumption. (https://www.nytimes.com/2022/05/04/world/asia/india-russia-oil.html).

  • Dubai Becomes Popular Destination for Wealthy Russians: The BBC reported on Thursday that Dubai has become a popular destination for wealthy Russians leaving the country, with property purchases in Dubai by Russians surging by 67 percent in the first three months of 2022. The country has not imposed sanctions on Russia and is willing to issue visas to non-sanctioned Russians. Business analysts in Dubai have also noticed an uptick in Russian companies moving to Dubai; they suspect that wealthy Russians are moving their capital before the Russian economy deteriorates further. (https://www.bbc.com/news/business-61257448).

  • Serbia to Begin Negotiations with Russia for Gas Supply: Serbian President Alexsandar Vucic stated that Serbia would begin a new round of negotiations with Russia regarding natural gas supply in the coming years. Serbia’s current contract expires on May 31, and the country is seeking another long-term contract. President Vucic added that the country is completely dependent on Russian gas, and new pipelines to get natural gas supplies from other countries would take at least 300 days to come online. (https://tass.com/economy/1447253).


May 04, 2022

  • Australia Imposes Sanctions on 110 More Individuals: On Wednesday, Australian Foreign Minister Marise Payne announced sanctions on an additional 110 individuals due to the Russian war in Ukraine. The sanctions target “senior Ukrainian separatists and Russian members of parliament,” and include 34 senior members of the so-called “People’s Council of the People’s Republic of Donetsk” and “People’s Council of the People’s Republic of Luhansk.” The sanctions impose financial and travel restrictions on the targets. (https://www.foreignminister.gov.au/minister/marise-payne/media-release/additional-sanctions-response-russias-invasion).

  • China Reportedly Runs “Stress Test” for Possible Future Sanctions: On Wednesday,The Guardian reported that various Chinese government agencies, from banking regulation to international trade, were asked in early March to come up with a response plan if the international community imposed sanctions on China similar to those already imposed on Russia. Chinese government representatives said that the exercise was a “natural response” given Beijing’s close ties to Moscow. (https://www.theguardian.com/world/2022/may/04/beijing-orders-stress-test-as-fears-of-russia-style-sanctions-mount).   

  • Chinese Independent Refineries Purchasing Russian Oil: On Wednesday, The Financial Times reported that Chinese independent refiners have been purchasing Russian oil at a steep discount as a result of sanctions on Russia. Chinese state-owned oil refiners are largely avoiding purchases of Russian oil to avoid provoking western governments, but independent refiners are making purchases of Russian oil at $35 below market. Overall, Chinese imports of Russian oil are about 86,000 barrels per day higher this month than they were on average last year. (https://www.ft.com/content/4f277a24-d681-421a-9c94-29d6fd448b20).


May 02, 2022

  • Japanese Company Proceeds with Russian LNG Extraction Project: On Monday, The Wall Street Journal reported that Kenichi Hori, the head of Japanese trading and investment company Mitsui, said that the company will continue with its investment in a Siberian natural gas extraction project, Arctic LNG 2. The move comes after French energy company Total announced that it took a $4.1 billion accounting charge on the Arctic LNG 2 project, since it could no longer count on anticipated reserves in the project given continued sanctions on the Russian energy sector. Mitsui wrote down the value of the project by 36.4 million yen, but believes the project still has value. (https://www.wsj.com/articles/japan-pushes-ahead-with-plan-to-add-russian-gas-imports-11651491927?mod=livecoverage_web).


May 01, 2022

  • Chinese Regulators Meet with Banks to Prepare for Future Russia-Style Sanctions: Per aFinancial Times report, Chinese regulators met with representatives from domestic and foreign banks on potential responses to restrictions on the use of the dollar and SWIFT system, should the United States impose sanctions on China similar to those already in place on Russia. The attendees did not mention a specific situation that would trigger such sanctions, but analysts suspect a Chinese invasion of Taiwan may provoke international response. (https://www.ft.com/content/45d5fcac-3e6d-420a-ac78-4b439e24b5de).


April 29, 2022


April 28, 2022

  • UBS Holds $22 Billion in Assets Due to Sanctions: In its quarterly report, UBS stated that it is holding roughly $22 billion in assets for Russian clients potentially impacted by EU and Swiss sanctions on prominent Russians. It declared that 0.7 percent of its invested assets in its wealth management divisions were held by “Russian persons not entitled to residency in the European Economic Area (EEA) or Switzerland.” (https://www.reuters.com/business/ubs-holds-22-bln-russians-not-resident-switzerland-or-eea-2022-04-26/).

  • Japan Protests Expulsion of Diplomats:Speaking in a Thursday press briefing, Japanese Chief Cabinet Secretary Hirkazo Matsuno publicly protested Russia’s decision to expel eight Japanese diplomats from its territory. He blamed Moscow for the deterioration in bilateral relations between Japan and Russia. Japan previously expelled eight Russian diplomats from its territory. (https://www.japantimes.co.jp/news/2022/04/28/national/russia-expels-japan-diplomats/).   


April 27, 2022

  • Chinese Drone Maker Withdraws from Russia:In a brief statement on Tuesday, Chinese drone maker DJI, the largest drone maker in the world,which is listed by the U.S. on the Entity List and Non-SDN Communist Chinese Military Companies List, announced “it is internally reassessing compliance requirements in various jurisdictions” and would “temporarily suspend all business activities in Russia and Ukraine” due to ongoing hostilities. It is one of the few Chinese companies to suspend operations in Russia since the conflict in Ukraine began, though the company has fielded criticism from the Ukrainian government that their drones were being used by the Russian military. (https://www.washingtonpost.com/world/2022/04/27/china-drones-dji-russia-suspension-war/).

  • Switzerland Harmonizes Sanctions with Fifth EU Package: On Wednesday, Switzerland announced that it had aligned its current sanctions regime with restrictions in place in the EU. Switzerland implemented new import restrictions on Russian revenue products, like coal and caviar, and export restrictions on industrial products. The new restrictions also limit support to Russian entities in public ownership or under public control, and limits trust registration in Switzerland for Russian nationals. However, the country did not implement the EU bans concerning the award of public contracts to Russian nationals and organizations or entities established in Russia, instead waiting for the government to properly asses distribution of responsibility between the federal government and the cantons. It also is permitted to export special equipment to protect against nuclear, biological, and chemical warfare due to a request for assistance from the Organization for the Prohibition of Chemical Weapons. (https://www.admin.ch/gov/en/start/documentation/media-releases.msg-id-88265.html).

  • SkyTeam Suspends Aeroflot Membership:International airline alliance SkyTeam announced on Wednesday that it had suspended the membership of Aeroflot, Russia’s flag carrier airline. During the suspension, the company may still use SkyTeam trademarks, but SkyTeam customers will not receive alliance benefits while traveling on Aeroflot flights. (https://tass.com/economy/1444355).


April 26, 2022

  • India Struggling to Move Russian Oil Due to Sanctions: India’s Oil and Natural Gas Corp (“ONCG”), which has a stake in Russian oil extraction projects, is having difficulty finding ships to transport Russian oil, based on a Tuesday report from Reuters. ONCG relies on Sovcomflot to provide ships with ice breaking capability, and Western companies are refraining from insuring the trips due to Western sanctions. Non-sanctioned shipping companies are also more cautious about providing support for Russian oil transactions. (https://www.reuters.com/business/energy/indias-ongc-struggling-move-russian-oil-asia-sanctions-bite-sources-2022-04-26/).


April 22, 2022

  • Australia Sanctions Additional Russians: On Friday, Australian Foreign Minister Marise Payne announced that the Australian government had imposed targeted financial sanctions on 147 more individuals. The sanctioned individuals include the 144 Russian Senators that voted to approve the recognition of the Donetsk and Luhansk People’s Republics, and the daughters of Russian President Vladimir Putin and Russian Foreign Minister Sergei Lavrov. The sanctions restrict the individuals’ ability to enter Australia and to conduct financial transactions in Australia. (https://www.foreignminister.gov.au/minister/marise-payne/media-release/additional-sanctions-russia).

  • Major Indian Companies Leaving Russia: Indian steel producer Tata Steel announced that it “has taken a conscious decision to stop doing business with Russia.” The statement added that all steel manufacturing operations in India, the UK, and the Netherlands have sourced alternative raw material supplies to end its dependence on Russia. Indian technology company Infosys also announced it was moving operations out of Russia, which will include relocating work centers currently in the country. (https://www.cnn.com/2022/04/21/business/india-tata-steel-infosys-stops-russia-business-hnk-intl/index.html).


April 21, 2022

  • Serbia Will Not Sanction Russia: In an interview published with The Financial Times on Thursday, Serbian President Aleksandar Vucic stated that the country will not impose sanctions on Russia. He stated, “we have not imposed sanctions against anyone, because… we don’t believe sanctions change anything.” Serbia is a candidate for EU membership, and the bloc has privately expressed frustration at Serbia’s lack of willingness to sanction Russia. (https://www.ft.com/content/0041d1a9-7fbd-4ea3-8176-e8b7d99e4a92).


April 20, 2022

  •  Japan Revokes Most-Favored-Nation Status with Russia: On Wednesday, the Japanese parliament formally enacted a law revoking Russia’s most-favored-nation trade status. The revocation, which enters into effect later this month, will apply tariffs on most products imported from Russia to Japan. The legislation also revises foreign exchange laws to prevent transfers of virtual currency by parties that are subject to Japanese asset freezes. (https://apnews.com/article/russia-ukraine-business-tokyo-europe-moscow-e264ff718a4c998fe66c67e687864b12).

  • Switzerland to Maintain Nondisclosure Rules on Russian Oil Trades: On Tuesday, the Swiss State Secretariat for Economic Affairs announced that it would decide on a case-by-case basis to curtail oil trades from Russian state-controlled companies, even though the country has adopted sanctions that limit commodity deals to “strictly necessary” transactions beginning in mid-May. The government will also keep conversations with trading houses confidential. (https://finance.yahoo.com/news/swiss-keep-mum-russian-commodity-074242119.html).


April 19, 2022

  •  IMF Reduces Global Growth Forecast, in Part Because of Ukraine Conflict: On Tuesday, the International Monetary Fund (“IMF”) announced that it expects the world economy to expand by 3.6 percent in 2022, a decrease of 0.8 percent from its January assessment. It cited the war in Ukraine as a primary reason for the downgrade, saying the conflict will disrupt global supply chains in the energy and commodity sector. The assessment also assumes that the conflict will remain contained to Ukraine and that future sanctions will not target the Russian oil sector. Looking at both Russia and Ukraine specifically, the IMF expects the Ukrainian economy to contract by 35 percent this year, while it expects the Russian economy to contract by 8.5 percent this year. (https://www.cnn.com/2022/04/19/investing/imf-economic-outlook/index.html).

  • IMF Warns that Digital Currency Mining May Dodge Sanctions: In a Tuesday report, the International Monetary Fund (“IMF”) warned that heavily sanctioned countries like Russia and Iran may use their energy reserves, which are restricted in international markets, to develop domestic coin mining infrastructure, a heavily energy-intensive process. The report warns that, in turn, the countries could use transaction fees on the mined coins to fund their governments. (https://www.bloomberg.com/technology).  


April 18, 2022

  • Emirates to Continue Flights to Russia Unless Ordered to Stop: Speaking to the BBC on Monday, Emirates Airlines President Sir Tim Clarke stated that the airline will continue its flights to Russia, saying “if we are told to stop we will stop, unless we are told otherwise, we will continue.” He added that it was up to the UAE government to ban flights. Emirates is one of the last major international airlines to continue flights to Russia. (https://www.bbc.com/news/business-61140802).

  •  Serbian President Confirms Serbian Air Flights to Russia Will Continue: Speaking on Monday, Serbian President Aleksandar Vucic stated that the country’s national carrier, Air Serbia, will continue flights to Russia. He added that the carrier has consistently received bomb threats for flights scheduled for Russian destinations. (https://tass.com/world/1438913).

  • Japanese Public Opinion Polling Shows Support for Sanctions: According to a Kyodo News survey published on Sunday, more than seven in 10 Japanese people, or 73.7 percent, support economic sanctions against Russia, even if the sanctions impact Japanese daily life. This polling number outpaced approval ratings for Prime Minister Fumio Kishida’s cabinet, which stood at 58.7 percent, a slight decline for 60.1 percent approval in March. (https://www.japantimes.co.jp/news/2022/04/17/national/japanese-support-russia-sanctions/).

  • Russia Shipping Fertilizer to Brazil Despite Sanctions: According to shipping data accessed on Monday, at least 24 vessels carrying almost 678,000 tons of Russian fertilizers from ports in the country are expected to reach Brazil in the next weeks. These volumes indicate that Brazil continued purchasing fertilizer from Russia, despite the imposition of international sanctions that threatened to disrupt Russian industry. (https://finance.yahoo.com/news/ships-carrying-russian-fertilizers-way-183433719.html


April 15, 2022

  •  IMF Downgrades Global Growth Forecasts Due to Ukraine Conflict, COVID: On Thursday, the International Monetary Fund downgraded its global growth forecast for 143 countries, representing 86 percent of global GDP.


April 14, 2022

  • China Expresses Intent to “Defend the Legitimate Rights of Companies”: Speaking to a Thursday press conference, Chinese Commerce Ministry Spokeswoman Shu Juteng stated that China will resist attempts to “choose sides” in the Russia-Ukraine conflict, and instead “take the necessary measures and firmly defend the legitimate rights of companies.” She reiterated that China will not sanction Russia without UN approval. (https://tass.com/world/1437531).


April 13, 2022

  • Switzerland Matches EU Sanctions: On Wednesday, the Swiss Federal Council took action to match the Swiss sanctions program to the one in place in the European Union. This includes asset freezes on 200 more individuals; import bans on Russian coal and revenue products, like wood, cement, seafood, and vodka); public procurement bans for Russian companies; and financial restrictions on trusts and Russian public institutions. (https://www.admin.ch/gov/en/start/documentation/media-releases.msg-id-88028.html).

  • Vitol to Stop Purchasing Russian Crude by Year’s End: On Wednesday, Vitol, the world’s leading independent oil trader, announced that it would stop trading Russian crude oil and products by the end of the year. The move comes as many oil companies and countries restrict purchases of Russian oil products. (https://www.cnn.com/2022/04/13/business/vitol-russian-oil/index.html).


April 12, 2022

  • Japanese Cabinet Approves New Sanctions: On Tuesday, the Japanese cabinet approved an asset freeze on 398 Russian entities (including children of Russian President Vladimir Putin and Russian Foreign Minister Sergei Lavrov) and an import ban on 38 items, including Russian vodka, liquor, and lumber. Prime Minister Fumio Kishida previously announced the measures on Friday, April 9. The measures will enter into force on April 19. (https://www.mofa.go.jp/mofaj/files/100330734.pdf).

  • WTO Downgrades World Trade Forecast due to Ukraine Conflict and COVID: On Tuesday, the World Trade Organization (“WTO”) revised its forecast for global trade growth in 2022 down, from 4.7 percent to 3.0 percent. The organization cited the war in Ukraine’s impact on global food prices, which, combined with unresolved supply chain issues from the pandemic, will reduce the global trade outlook. (https://www.reuters.com/business/wto-lowers-its-2022-global-trade-growth-forecast-2022-04-12/).


April 11, 2022

  • Japanese Pharmaceutical Companies Suspend New Activity in Russia: On Sunday, Japanese pharmaceutical companies Takeda and Astellas Pharma announced that they had suspended new clinical trials and new investment in Russia. Ongoing clinical trials in Russia will continue, as will shipments of medication from Japan to Russia. (https://tass.com/economy/1435357).


April 8, 2022


April 7, 2022

  • Australia Sanctions 67 Additional Russian Entities: On Thursday, Australian Foreign Minister Marise Payne announced sanctions on an additional 67 Russian entities. The sanctioned individuals include Deputy Prime Minister Dmitry Grigorenko, Minister of Economic Development Maxim Reshetnikov, Deputy Chairman of the Russian State Duma, Aleksander Babakov, and other senior Russian government officials. The restrictions impose targeted financial sanctions and travel bans on the listed individuals. (https://www.foreignminister.gov.au/minister/marise-payne/media-release/further-russia-sanctions).


April 6, 2022

  • Switzerland’s Sanction Regime Reaches Limit:Though Swiss sanctions have frozen an estimated $6 billion in Russian assets located in the country and frozen access to 10 properties, Bloomberg released an article on Wednesday saying that the Swiss sanctions authorities were almost entirely reliant on banks self-reporting assets held by sanctioned parties. With the expanded scope of sanctions, and limited experience in enforcing sanctions without cooperation, Swiss sanctions authorities face enforcement challenges. (https://news.bloomberglaw.com/banking-law/swiss-hunt-for-russian-wealth-criticized-despite-6-billion-haul).


April 5, 2022


April 4, 2022

  • Russian Oligarchs Reportedly Buying Up Swiss Art: Sources within the Swiss fine art community are reporting a noted uptick in interest from Russian buyers, driven by Switzerland’s looser restrictions on cash transactions and limited tracing of those transactions as compared to the EU. The new sanctions regime has also drawn increased scrutiny to the Geneva Freeport, a bonded warehouse with limited monitoring for beneficial ownership that is known for holding significant amounts of luxury goods and art. (https://www.theartnewspaper.com/2022/04/04/freeport-secrecy-veils-oligarch-art-assets).

  • Moldova Will Not Assist in Sanctions Evasion:On Monday, Moldovan President Maia Sandu announced, “We will foil reexports via the Republic of Moldova [to Russia].” She added that the country’s banks are observing bans on international payment systems on Russian banks. (https://tass.com/world/1432099).


April 3, 2022

  • Japan to Continue Sanctions Until War Ends:Speaking with a national broadcasting outlet on Sunday, Japanese Trade Minister Koichi Hagiuda stated that Japan will increase sanctions on Russia, in coordination with international partners, “until a peace agreement with Ukraine becomes clear.” He added that, while the Japanese government has not directly restrained Russian businesses operating in Ukraine, it will become difficult for them to operate in Russia if the war continues. (https://www.bloomberg.com/news/articles/2022-04-03/russia-sanctions-will-only-increase-until-peace-japan-s-hagiuda).


April 1, 2022


March 31, 2022

  • Kazakhstan Seeks to Attract European Companies Leaving Russia: First Deputy Chief of Staff to the Kazakh President Timur Suleimenov underlined the “opportunities” Russia’s invasion of Ukraine created for Kazakhstan to attract European businesses in a Thursday interview with Politico. Kazakhstan has a privileged access to the Russian market through the Eurasian Economic Union and claims that the European Commission supports the move as long as the sanction regime is respected. (https://www.politico.eu/article/kazakhstan-says-it-will-help-eu-companies-sell-t-shirts-and-sneakers-to-russia/).


March 30, 2022

  • China Praises Cooperation with Russia: In a Wednesday statement, Chinese Foreign Ministry Spokesman Wang Wenbin said “The cooperation between Russia and China has no boundaries.”He also noted that China was ready to assist with negotiations between Russia and Ukraine that would end the conflict, and that China will continue providing humanitarian assistance to Ukraine. (https://tass.com/world/1429541).


March 28, 2022

  • Australia Announces First-Ever Magnitsky Sanctions: On Tuesday, Australian Foreign Minister Marise Payne announced that it will be sanctioning 39 Russian individuals, 14 Russians responsible for the corruption that Mr. Magnitsky uncovered, and 25 perpetrators and accomplices of his abuse and death. Foreign Minister Payne said that this was the first tranche of sanctions imposed under Australia’s “Magnistky-style” sanctions reforms passed in December 2021. (https://www.foreignminister.gov.au/minister/marise-payne/media-release/australias-first-magnitsky-style-sanctions).

  • Japan Imposes New Export Controls: On Tuesday, the Japanese Ministry of Trade announced that it had restricted the export to Russia of the following items: cars worth more than 6 million yen; jewelry, watches, cosmetics, and art priced at more than 40,000 yen; boat engines worth more than 1.3 million yen; motorcycles worth over 600,000 yen; and grand pianos worth more than 200,000 yen. Most Japanese auto exports to Russia fall below the 6 million yen threshold. The restrictions go into effect on April 5, 2022. (https://www.reuters.com/business/autos-transportation/japan-ban-russia-bound-exports-luxury-cars-goods-april-5-2022-03-29/


March 28, 2022

  • Japan to Modify Foreign Exchange Law to Prevent Sanctions Evasion through Crypto: On Monday, Japanese Chief Cabinet Secretary Hirozaku Matsuno announced that the government will submit a revision to the Foreign Exchange and Foreign Trade Act to parliament in order to prevent digital assets from being used as a tool for sanctions evasion. Though government representatives were unwilling to provide specific details on the amendment, Saisuke Sakai, senior economist at Mizuho Research and Technologies, told Reuters that he expects the revision to “enable[] the government to apply the law to crypto-asset exchanges like banks and oblige them to scrutinize whether their clients are Russian sanction targets.” (https://www.reuters.com/world/asia-pacific/japan-revise-foreign-exchange-law-end-crypto-loophole-sanctions-russia-2022-03-28/).

  • Western Companies Fear Paying Rent on Moscow: Several major Western financial institutions, industrials and law firms are struggling to determine whether paying rent on their Moscow offices would breach sanctions because of potential links to sanctioned oligarch, Roman Abramovich. This highlights the practical challenges faced by international companies continuing to operate in Russia. (https://www.ft.com/content/368a7468-f6ca-4b5b-a2e8-d827c2eb6e05).


March 27, 2022

  • Japanese Banks Stop Dollar Transactions with Sberbank: In response to US sanctions, Japan’s three largest banks, MUFG Bank, Mizuho Bank, and Sumitomo Mitsui Banking Corp announced that they were suspending dollar-denominated transactions with Sberbank, as the US ban on dollar transactions with Sberbank went into effect yesterday. Sources close to MUFG Bank stated that the bank will also refrain from sending money to Sberbank in other foreign currencies. (https://japantoday.com/category/business/major-japan-banks-to-halt-dollar-transactions-with-russia%27s-sberbank).

  • Qatar Holding Off on Further Investment in Russia: During a Sunday CNN interview, Qatar’s Minister of Foreign Affairs, Sheikh Mohammed bin Abdulrahman Al-Thani stated that the government is reviewing its current investments in Russia and is not planning on new investment in Russia until there is a “better environment and more political stability.” The Qatar Investment Authority holds a significant stake in Rosneft, which the Foreign Minister stated would not increase in the immediate future. (https://www.cnn.com/europe/live-news/ukraine-russia-putin-news-03-27-22/h_e80f630c22ea6ba9bb3d9fc5e5f9f990).

  • Yale School of Management Releases List of Multinational Corporations and their Position Toward Russia: On Sunday, the Yale School of Management published a list of over 450 major multinational corporations and their current position toward Russia, from “digging in” (defying demand for reduction of activities) to full withdrawal from Russia. (https://som.yale.edu/story/2022/over-450-companies-have-withdrawn-russia-some-remain).

  • Wall Street Journal Highlights US, EU Differences in Sanctions Policies: Over the weekend, The Wall Street Journal released an article summarizing this week’s NATO meetings and their impact on sanctions. The article highlights division between the US and EU with regards to energy sanctions; the US is more willing to impose restrictions on the sector, but EU countries fear the restrictions would harm the EU more than Russia. The article also discusses secondary sanctions, which the US is reportedly exploring. Some EU countries see secondary sanctions as an extraterritorial abuse of power. Finally, the article mentions that the US has not imposed sanctions on some oligarchs that are facing restrictions in the EU. (https://www.wsj.com/articles/u-s-europe-unity-on-ukraine-shows-limits-amid-differences-on-russia-sanctions-11648299833).  


March 25, 2022

  • Switzerland Aligns Sanctions with EU: On Friday, the Swiss Federal Council announced new sanctions to remain consistent with those imposed by the European Union. These actions include an export ban on goods for the energy sector to Russia, a financing ban on the Russian energy sector, steel imports from Russia, and an export ban on luxury goods and maritime navigation tools to Russia. The measures enter into force at 11pm. Switzerland notably declined to extend the EU’s ban on Russian news outlets Russia Today and Sputnik. (https://www.admin.ch/gov/en/start/documentation/media-releases.msg-id-87747.html).  

  •  Prime Minister Trudeau Previews New Restrictions: In appearances at the NATO summit, Canadian Prime Minister Justin Trudeau announced that Canada would be imposing sanctions on 160 members of the Russian Federation Council and new export controls on certain goods and technologies to Russia “in the coming days.” (https://www.reuters.com/article/us-ukraine-crisis-canada-idCAKCN2LL25M).

  • Chinese Businesses Increasing Outreach to Treasury Department: Despite concerns that Chinese companies would seek to avoid US sanctions on Russia, Bloomberg is reporting that the Treasury Department is receiving an increasing number of requests from Chinese companies seeking to comply with new sanctions laws. However, some officials remain concerned that these requests are an attempt to locate loopholes in the existing sanctions packages. (https://news.bloomberglaw.com/international-trade/china-damps-u-s-concern-on-sanctions-by-drilling-into-details). 


March 24, 2022

  • UN General Assembly Approves Resolution on the Humanitarian Consequences of the Aggression Against Ukraine: The UN General Assembly approved by an overwhelming majority a resolution on March 24, 2022 blaming Russia for the humanitarian crisis in Ukraine and urging an immediate cease-fire and protection for millions of civilians and the homes, schools and hospitals critical to their survival. Only Belarus, Syria, North Korea, Eritrea and Russia opposed the resolution, while 38 States abstained. This follows the rejection by the UN Security Council yesterday of a resolution put forward by Russia which omitted Russia’s invasion. (https://apnews.com/article/russia-ukraine-united-nations-general-assembly-europe-united-nations-5cc9c2eddfd38e6cf07e1582854e7c94).


March 23, 2022


March 22, 2022

  • Japan Protests Russian Withdrawal from Peace Talks: After Russia announced on Monday that it was withdrawing from the Kuril Island peace talks with Japan due to Japanese sanctions on Russia, Japanese Prime Minister Fumio Kishida criticized the withdrawal as “completely unacceptable” in a Tuesday interview. He reiterated Japan’s commitment to the international sanctions regime on Russia in his interview. (https://www.reuters.com/world/russia-halts-japan-peace-treaty-talks-over-sanctions-2022-03-21/).

  • Malaysia, Vietnam Commit to Neutrality in Russia-Ukraine Conflict: During a visit to Hanoi, Malaysian Prime Minister Ismail Sabri Yaakob stated that he discussed the Russia-Ukraine conflict with Vietnamese Prime Minister Pham Minh Chinh, and noted that the two countries agreed to remain neutral in the conflict. (https://tass.com/economy/1425683).


March 20, 2022

  • Australia Bans Alumina Exports to Russia: On Sunday, Australia announced that it would ban all exports of alumina and aluminum ores, including bauxite, to Russia, effective immediately. According to the statement announcing the restrictions, Russia relies on Australia for 20 percent of its alumina needs. (https://www.pm.gov.au/media/additional-support-ukraine).

  • Chinese Vice Foreign Minister Criticizes International Sanctions Regime: In a Saturday statement, Chinese Vice Foreign Minister Le Yucheng said that international sanctions against Russia are getting “more and more outrageous,” adding that Russians were having overseas assets frozen “for no reason.” He also noted, “History has proven time and again that sanctions cannot solve problems. Sanctions will only harm ordinary people, impact the economic and financial system… and worsen the global economy.” (https://www.reuters.com/world/chinese-official-calls-sanctions-russia-increasingly-outrageous-2022-03-19/).


March 18, 2022

  • New Zealand Sanctions Enter Into Force: After passage of a new sanctions law specific to the conflict in Ukraine, the New Zealand government announced its first round of sanctions on Russian entities. The targets include President Vladimir Putin and 12 members of his security council, and 19 organizations, including the Cossack National Guard, PSB bank, and JSC Integral. The sanctions ban the entry of any person on the list into New Zealand, block the entry of any of their ships or aircraft, and prevent New Zealand nationals from transacting with any named party. (https://www.newsroom.co.nz/nzs-first-round-of-russia-sanctions-revealed).


March 17, 2022


March 16, 2022

  • Switzerland Aligns Sanctions with EU: On Tuesday, Swiss Federal Councillor Guy Parmelin, the head of the Federal Department of Economic Affairs, Education and Research (EAER), announced that Switzerland would place financial sanctions and travel restrictions on 197 new individuals and 9 new entities, in order to match the country’s sanctions program with measures imposed by the European Union. (https://www.admin.ch/gov/en/start/documentation/media-releases.msg-id-87619.html).

  • Japan to Revoke MFN Status with Russia: During a Wednesday news conference, Japanese Prime Minister Fumio Kishida announced that Japan would revoke most-favored-nation (“MFN”) status for Russia. This move follows announcements by other G7 countries that they would “endeavor” to take the measure. Prime Minister Kishida also announced that Japan was planning to expand its list of banned exports to Russia to include luxury goods, and add names to its asset freeze list. (https://www.japantimes.co.jp/news/2022/03/16/national/russia-most-favored-nation-status-revoke/).


March 15, 2022


March 14, 2022

  • Australia Sanctions 33 More Oligarchs: On Monday, Australian Foreign Minister Marise Payne announced that it will sanction 33 more Russian oligarchs, in line with measures already taken by the US and UK. The parties include Roman Abramovich, Chelsea Football Club owner; Alexey Miller, CEO of Gazprom; Dmitri Lebedev, Chairman of Rossiya; Sergey Chemezov, Chair of Rostec; Nikolay Tokarev, CEO of Transneft; Igor Shuvalov, Chairman of Vnesheconombank (VEB.RF); and Kirill Dmitriev, CEO of the Russian Direct Investment Fund (RDIF). (https://www.foreignminister.gov.au/minister/marise-payne/media-release/australia-joins-uk-and-us-sanctioning-key-russian-oligarchs).
  • Japan Orders Crypto Exchanges to Not Process Russian Linked Transactions: On Monday, the Japanese Financial Services Agency and the Ministry of Finance announced that they would be restricting transactions on a crypto-asset exchange made in circumvention of sanctions on Russia and Belarus. Any payments with sanctioned entities can only be made with permission from the government, or risk three years in prison or a 1 million yen fine. (https://www.mof.go.jp/policy/international_policy/gaitame_kawase/press_release/20220314.html) (Japanese).


March 13, 2022

  • Japan’s Mitsui and Mitsubishi to remain in Russia’s Sakhalin-2 LNG project, while Japan to pursue long-term plan to reduce dependence on Russian energy.  Despite Shell exiting a landmark LNG plant that has served as a symbol of cooperation between Tokyo and Moscow, Japanese trading houses Mitsui & Co. and Mitsubishi Corp. are sticking with the Sakhalin-2 project, the source of nearly 10% of Japan’s liquefied natural gas imports.  https://asia.nikkei.com/Business/Energy/No-easy-exit-for-Japan-from-Russia-s-Sakhalin-2-LNG-project


March 12, 2022


March 11, 2022


March 10, 2022

  • Japanese Companies Exit Russia: On Thursday, Japanese gaming companies Sony Interactive Entertainment and Nintendo announced that they would be halting shipments to Russia and closing all stores in Russia “for the foreseeable future.” Electronics manufacturer Hitachi also announced that it would suspend operations in Russia on Thursday, citing supply chain issues. (https://www.aljazeera.com/economy/2022/3/10/japans-sony-and-nintendo-halt-business-in-russia).


March 09, 2022


March 08, 2022

  • Australia Announces New Sanctions: Australian Foreign Minister Marise Payne announced another round of sanctions in response to Russia’s invasion of Ukraine, this time targeting members of the Russian Armed Forces. The restrictions ban travel for 6 senior Russian military commanders and 10 people of strategic interest to Russia for “encouraging hostility toward Ukraine and promoting pro-Kremlin propaganda.” The government also directly sanctioned the Russian Armed Forces as a whole, banning export of Australian goods to entities that supply the Russian military. (https://www.foreignminister.gov.au/minister/marise-payne/media-release/further-sanctions-russia).

  • South Korea Receives Exclusion for US Foreign Direct Product Rule: In a joint statement, the Republic of Korea’s Minister of Trade, Industry and Energy Moon, Sung Wook and Secretary of Commerce Gina M. Raimondo announced Korea’s formal addition to the global coalition of nations opposing Russian aggression in Ukraine. This addition adds the Republic of Korea to the list of countries to receive and exclusion from license requirements under the US export controls on Russia and Belarus. (https://www.commerce.gov/news/press-releases/2022/03/joint-statement-republic-koreas-partnership-export-controls-russia).


March 07, 2022


March 04, 2022

  • Switzerland Announces New Sanctions: On Friday, the Swiss Federal Council approved a new round of sanctions and export controls on Russian entities. The changes come into force at 6pm on March 4. The new restrictions are:

    o  Export controls on dual-use items to Russia, regardless of end use or end user.

    o  Export controls on certain goods and services in the oil sector.

    o  A prohibition on public financing or financial assistance for trade with or investment in Russia.

    o  Support for the removal of certain Russian banks from SWIFT.

    o  Addition of individuals with close ties to President Putin to the Swiss asset freeze lists. (https://www.admin.ch/gov/en/start/documentation/media-releases.msg-id-87474.html).


March 03, 2022

  • Japan Belarusian Officials: On Thursday, Japan announced sanctions on 18 Russian officials, 4 Russian banks, 7 individuals and 2 entities from Belarus, and 30 individuals in DNR and LNR. Certain payments to the individuals will be allowed by notification to the Ministry of Foreign Affairs, and capital transactions (ie: deposit contracts) are allowed. The ministry will also investigate its current export controls on Belarus and enhance restrictions when necessary. (https://www.mofa.go.jp/mofaj/press/release/press4_009291.html (Japanese language release)).


March 01, 2022

  • US Praises South Korea for Support for SWIFT Cutoff: In a call with Korean Vice Minister of Economy of Finance Eog-weon Lee, Deputy Secretary of the Treasury Wally Adeyemo “welcomed the Korean government’s cooperation on removing key Russian banks from the SWIFT network and for its announcement of export controls on Russia.” (https://home.treasury.gov/news/press-releases/jy0617).


February 28, 2022

  • Swiss Federal Council Votes to Freeze Sanctioned Russian Assets: In a Monday vote, the Swiss Federal Council decided to adopt measures freezing assets of sanctioned Russian individuals, effective immediately. The Council also voted to impose sanctions on Russian President Vladimir Putin and Foreign Minister Sergei Lavrov, effective immediately. Swiss entities were already banned from engaging in new business relationships with sanctioned individuals. The Council also voted to restrict entry to Russian nationals close to President Putin and close airspace to Russian aircraft. (https://www.admin.ch/gov/en/start/documentation/media-releases.msg-id-87386.html).

  • South Korea Tightens Export Controls, Supports SWIFT Restrictions: In a February 28 statement, the South Korean Ministry of Foreign Affairs announced further measures to combat Russian aggression in Ukraine. It announced that it had completed a review of export controls on Russia, and would be strengthening controls on “strategic items” to the country. The Prime Minister said he would support the SWIFT restrictions In addition, it stated that relevant ministries were still reviewing “non-strategic” export controls on dual use items, like electronics, and would “finalize actionable measures” on those items in the near future. The Foreign Ministry also expressed support for the exclusion of Russian banks from SWIFT. (https://www.mofa.go.kr/eng/brd/m_5676/view.do?seq=322003).

  • Australia Supports G7 SWIFT, Central Bank Efforts, Sanctions Putin: In a Monday press statement, Australian Prime Minister Scott Morrison expressed support for G7 efforts to remove Russia from SWIFT, sanction the Russian central bank, establish an anti-sanctions task force, and eliminate “golden passports” for wealthy Russians. It also announced that sanctions on Russian President Vladimir Putin and the members of the Russian Security Council had gone into effect, restricting their access to Australian assets and preventing their ability to travel to the country. (https://www.pm.gov.au/media/economic-measures-against-russia-and-lethal-military-equipment-ukraine).

  • Singapore to Restrict Trade with Russia: In a Monday speech to parliament, Singapore Foreign Minister Vivian Balakrishnan said that the country would “act in concert with other like-minded countries to impose appropriate sanctions and restrictions on Russia.” He stated that these measures would include export controls on items that could be used as weapons in Ukraine and block “certain” Russian banks and transactions with Russia. Formal implementation of the measures will be announced “shortly.” (https://www.reuters.com/world/asia-pacific/singapore-impose-appropriate-sanctions-restrictions-russia-2022-02-28/).


February 27, 2022

White House Praises Announcement: White House Press Secretary Jen Psaki released a statement welcoming Prime Minister Kishida’s statement in support of SWIFT restrictions on select Russian banks. (https://www.whitehouse.gov/briefing-room/statements-releases/2022/02/27/statement-by-press-secretary-jen-psaki-on-japans-announcement-to-hold-russia-accountable/).


February 26, 2022

  • Canada Signs on to US and EU SWIFT, Central Bank, and Passport Restrictions: Canada is listed as one of the countries participating in the joint effort to remove certain Russian banks from SWIFT, sanction the Russian Central Bank, limit passport issuance, and participate in transatlantic sanctions coordination.
  • Eastern European Countries Close Airspace to Russian Carriers: Estonia, Latvia, Romania, and Slovenia announced on Saturday that they would ban Russian carriers and Russian-registered aircraft from their airspace. Estonian Prime Minister Kaja Kallas urged the entire EU to do the same in a tweet. Russia has been quick to impose retaliatory airspace closures for countries that impose restrictions on Russian aircraft, but none have been announced for this trio yet. (https://www.bbc.com/news/world-europe-60539303).


February 25, 2022

  •  Japan Expands Sanctions Program: On Friday, Japan announced an expansion of the sanctions it announced on Russia earlier in the week. The new measures include:

    o    A suspension of Japanese entry visas and a freeze on Japanese assets for designated Russian individuals;

    o    A freeze of Japanese assets of VEB, Promsvyazbank, and Bank Rossiya; and

    o    Sanctions of exports to Russian military end users, and export controls on dual use goods like semiconductors. (https://www.mofa.go.jp/press/release/press6e_000371.html).

  • Canada Imposes Two More Rounds of Sanctions, Calls to Remove Russia from SWIFT:

o  Late on 2/24, Canada released another round of economic sanctions. These measures include:

– Designation of 58 additional Russian individuals and entities. These individuals include members of the Russian Security Council and major financial institutions.

– Designation of 4 Ukrainian nationals said to be “pro-Russian agents of disinformation.”

– A halt on new export permit applications to Russia, and cancellation of valid export permits. The government will maintain a “limited number” of exceptions for critical medical supply chains. (https://pm.gc.ca/en/news/news-releases/2022/02/24/canada-announces-additional-measures-support-ukraine).

o  After changes through the day on Friday, the Canadian Prime Minister’s office announced a third round of sanctions. These measures include:

– Sanctions on Russian President Vladimir Putin, Russian Foreign Minister Sergei Lavrov, and President Putin’s Chief of Staff;

– Designated 57 Belarusian individuals that assisted in the Russian invasion of Ukraine; and

– Called for Russia to be removed from the SWIFT system. (https://www.cbc.ca/news/politics/ottawa-putin-sanctions-1.6365179).

  • Taiwan Joins International Sanctions Effort: On Friday, the Taiwanese Ministry of Foreign Affairs announced that it would join the international economic sanctions effort against Russia. Major semiconductor exporters in the country announced that they would comply with export control operations, as well.

    o In response, a spokesman for the Chinese Foreign Ministry said that this announcement was a chance to “grab eyeballs and try to make their presence felt… but this kind of trick will not prevail.” China is not planning to impose sanctions on Russia. (https://www.reuters.com/world/asia-pacific/taiwan-join-democratic-countries-sanctions-russia-2022-02-25/).

  • New Zealand Restrictions Announced: On Friday, New Zealand Prime Minister Jacinda Ardern announced that the country will implement travel bans on Russian government officials and citizens associated with the attack on Ukraine, suspend consultations between the Russian and New Zealand Foreign Ministries, and place a blanket ban on exports to the Russian military. New Zealand does not have its own sanctions legislation, so it did not announce any economic sanctions packages against Russian financial institutions. (https://www.wsj.com/livecoverage/russia-ukraine-latest-news/card/geXTLJoJnJkrAJ5Djpz2).


February 24, 2022

  • Switzerland Stops Short of Asset Freezes: Swiss President Ignazio Cassis stated that the country would expand on restrictions imposed on Russia after the 2014 annexation of Crimea and impose a reporting requirement for people on the EU sanctions list, preventing them from using Swiss territory from circumventing penalties; the expansion would now cover individuals sanctioned by the EU this week. However, sanctioned entities can still access their Swiss bank accounts and withdraw money. The Swiss government has not yet made a further decision on asset freezes. The reporting requirements still need to be approved by the Swiss Federal Council, which could take several days. (https://www.politico.eu/article/switzerland-drags-feet-on-sanctions-against-russia-after-ukraine-invasion/)

  • South Korea to Participate in Global Export Control Programs: The South Korean Foreign Ministry announced that it would be participating in US-led export control packages in response to Russia’s invasion of Ukraine. However, the country is not considering its own sanctions package against Russia. (https://en.yna.co.kr/view/AEN20220224011351325?section=national/diplomacy)

February 23, 2022

o   sanctions against members of Russia’s Security Council and several banks, including Rossiya, Promsvyazbank, IS Bank, Genbank and Black Sea Bank for Development and Reconstruction (in addition to investment ban on VEB)o   extension of existing sanctions on Crimea and Sevastopol to include Donetsk and Luhansk prohibiting trade in transport, energy, telecommunications and oil, gas and minerals sectors

o   planned expansion of designation criteria to include those of “strategic and economic significance to Russia”

    • Japan Announces Sanctions Against Russia (February 24, 2022)

      o   Prohibitions on trade with Donestk and Luhansk

      o   Prohibition of sovereign debt transactions (primary and secondary market) in Japan; expansion of coverage of maturity regarding existing prohibitions of bond issuances by designated Russian banks

      o   Asset freeze and travel bans on individuals determined to be involved in destabilizing Ukrainian territories

      Japan assessing potential Russian retaliation and contingency plans for supply chain disruption in key sectors, including chipmaking and energy  –https://asia.nikkei.com/Politics/Ukraine-crisis/Anticipating-retaliation-Japan-scrambles-to-review-Russian-imports

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