Russia & Ukraine

Since early March 2014, both the EU and the US have imposed sanctions on various individuals and entities in view of the ongoing situation in Eastern Ukraine and Crimea. The measures in place also include restrictions on dealings with Russiaʼs strategic oil sector and on financing of certain state corporations in Russia, as well as trade and investment bans concerning Crimea.

The initial measures imposed an asset freeze and travel ban against specific individuals involved in abuses of power and human rights in Ukraine (under EU Regulation 208/2014 in the EU and Executive Order 13660 in the US).

As the circumstances that led to the imposition of sanctions worsened, the measures in force were incrementally tightened through 2014. The EU and US have imposed asset freezes and travel bans directed against  key individuals deemed responsible for actions which undermine or threaten the territorial integrity, sovereignty and independence of Ukraine, as well as persons and entities associated with them. The EU measures are contained in EU Regulation 269/2014 of 17 March 2014 (as amended) and the US measures are in Executive Order 13661 of 16 March 2014.

Additional sanctions were imposed by the EU following the annexation of Crimea and Sevastopol by Russia during April 2014, including prohibiting the import of goods originating in Crimea or Sevastopol into the EU and the provision of financing or financial assistance as well as insurance and reinsurance related to such imports. The sanctions also prohibited the provision of financial loans or credit relating to: (i) the acquisition, creation or development of infrastructure in the areas of transport, telecommunications or energy in Crimea or Sevastopol and (ii) the exploitation of oil, gas or mineral resources in Crimea or Sevastopol. These prohibitions are contained in EU Regulation 692/2014 (as amended).

In late July 2014 the US and EU broadened the sanctions regime beyond targeting specific individuals to include measures directed against key sectors of the Russian economy. This “sectoral” sanctions approach has restricted access to capital markets for certain Russian state-owned banks and oil companies, restricted the export of “sensitive” technologies and imposed an arms embargo. These “sectoral” sanctions were imposed by the US under the auspices of Executive Order 13662 and the EU measures are set out in EU Regulation 833/2014 (as amended).

In view of the ongoing involvement of Russia in the crisis in Ukraine, the EU and the US have continued to expand the list of designated individuals subject to asset freezes and travel bans and the “sectoral” sanctions were expanded by the US and the EU in September 2014.

The US has coordinated its approach with the EU, though it has also demonstrated a willingness to target a wider group of persons including individuals considered to be close to President Vladimir Putin.

Key areas:

  • Sectoral sanctions targeting Russia’s access to capital markets and Arctic, deep water or shale oil exploration and production activities
  • Individual asset freezes and travel bans
  • Crimea trade and investment ban and a military equipment embargo

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