The UN, EU and US initiated sanctions programmes against Russia in the months following the country’s March 2014 annexation of the Ukrainian province of Crimea. Measures were strengthened in subsequent months in response to Russian involvement in civil conflict in Eastern Ukraine, which saw a number of provinces gain de facto independence from Kiev. US measures against Russia were further strengthened in 2016 and 2017 via the Countering America’s Adversaries Through Sanctions Act, which targets supporters of Russian President Vladimir Putin, and legislation seeking to penalise Russian alleged interference in the 2016 US Presidential election.
The sanctions on Russia have been significantly strengthened following Russia’s invasion of Ukraine on 24th February 2022.
Sanction Name
Restrictive Measures In Response To The Illegal Annexation Of Crimea And Sevastopol
First Imposed
Last updated
Targets
Trade Restrictions:
• Ban on the importation of goods from or investment in assets in Crimea or Sevastopol. Prohibition of the export to Crimea and Sevastopol of goods and technology for use in the sectors of transport, telecommunications, energy, oil, gas, infrastructure and mineral resources or related services, as well as services related to tourism. Prohibition of certain ships from entering ports in Crimea and Sevastopol.
These measures were adopted in response to acts of violence committed by Hamas and the DIP, which constitute serious violations of international humanitarian law and international human rights law.
Sanction Name
Restrictive measures in response to the recognition of the non-government controlled areas of the Donetsk and Luhansk oblasts of Ukraine and the ordering of Russian armed forces into those areas.
SANCTIONS
First Imposed
Last updated
Targets
Trade Restrictions:
•Prohibit the importation of goods from or investment in assets in the so-called Donetsk People’s Republic (“DNR”) or the Luhansk People’s Republic (“LNR”). Prohibition of the export to the DNR and LNR of goods and technology for use in the sectors of transportation, telecommunications, energy, oil, gas, infrastructure and mineral resources or related services, as well as services related to tourism.
•Prohibit the sale, supply, transfer or export of maritime navigation goods and technology to any person/entity in Russia, for use in Russia, or for the placing on board of a Russian-flagged vessel.
• The terms of measures against Russia to include anything which might contribute to Russia’s military or technological enhancement.
• Prohibitions on the provision of maritime transport, technical services or financial assistance related to the maritime transport of crude oil or petroleum products which originate in or are exported from Russia. Other sanctions include, but are not limited to, import restrictions on Russian products such as cigarettes and precious metals, restrictions on the sale or export of goods used in the aviation sector, amendments to export restrictions on items which may contribute to Russia’s military enhancement, including a prohibition on the sale of civilian firearms, a prohibition on the provision of crypto-asset wallets and a ban on the provision of architectural and engineering services, IT consultancy services and legal advisory services to the government of Russia or legal persons established in Russia. There are also sanctions imposed on individuals and entities deemed to have played a role in the organisation of the sham referenda in the Ukrainian regions of Donetsk and Luhansk.
Exemptions
Certain humanitarian and safety-related exceptions are available relating to the sale, supply, transfer or export of maritime navigation goods and technology to any person/entity in Russia, for use in Russia, or for the placing on board of a Russian-flagged vessel.
On 18th December 2023 the EU adopted the 12th package of Russia sanctions which included a ban from 1st January 2024 on non-industrial natural and synthetic diamonds originating or exported from Russia; a ban on Russia diamonds processed in third countries, including jewellery will be phased in progressively from March 2024 and completed by September 2024; a requirement for EU exporters to contractually prohibit re-exportation to Russia of sensitive goods and technology (such as items used in military systems and aviation goods) when selling to third countries; the designation of 61 individuals and 86 entities inclduing operators in the Russian military and defence sectors; expansion of the list of restricted items; restrictions on imports of goods such as pig iron; import ban on liquefied propane with a 12-month transitional period; and exemptions to import restrictions on personal use items, including hygiene, clothing, and cars; a greater enforcement of anti-circumvention measures; the enforcement of the oil price cap; and an iron and steel import ban.
On 29th January 2024 the European Council renewed for a further six months its restrictive measures in view of Russia’s continued actions in Ukraine, until 31st July 2024.
On 23rd February 2024 the European Council adopted the 13th package of restrictive measures against Russia in view of the second year mark of the Russian invasion of Ukraine. As part of the 13th package the EU imposed restrictive measures on an additional 106 individuals and 88 entities responsible for actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine. The new designations primarily target the military and defence sectors and associated individuals, including those involved in DPRK armament supply to Russia, as well as members of the judiciary, local politicians and people responsible for the illegal deportation and military re-education of Ukrainian children. Some of the entities are located in third countries (India, Sri Lanka, China, Serbia, Kazakhstan, Thailand, and Turkey) and have been involved in the circumvention of trade restrictions, others are Russian entities involved in the development, production and supply of electronic components for Russia’s military and industrial complex.
Sanction Name
Restrictive Measures In View Of Russia’s Actions Destabilising The Situation In Ukraine
SANCTIONS
First Imposed
Last updated
Targets
Arms Embargo, Trade Restrictions and Travel Ban:
• Prohibition on the provision of long-term financial or investment services to state-owned Russian financial institutions, the export of arms and related material and on the supply of dual-use goods and technology to military end-users, as well as services, goods and technology related to deep water, Arctic and shale oil prospecting. The procurement from Russia of arms and related materiel is prohibited, and there is also a ban on trading in certain bonds, equities and other financial instruments.
• All Russian Central Bank assets have been frozen and there is a ban on providing any loans or investments or investment services to the Government of Russia and the Central Bank.
• Ban on transactions with the Central Bank of Russia and prohibition of the acceptance of any deposits from Russian nationals if their total value exceeds €100,000.
• Ban on the provision of SWIFT services to Bank Otkritie, Novikombank, Promsvyazbank, Bank Rossiya, Sovcombank, VNESHECONOMBANK, Sberbank, Credit Bank of Moscow, the Russian Agricultural Bank, and VTB Bank. Investment participation or financing of the Russian Direct Investment Fund are also prohibited.
• Trade restrictions which prohibit the importation into the EU of Russian origin coal, wood, cement, fertilisers, seafood and liquor. Access to EU ports is prohibited for Russia-flagged vessels and there are a range of specific export bans on sensitive products such as jet fuel, quantum computers and high-end electronics.
•An import ban on Russian crude oil and petroleum products, export measures on 92 entities and a suspension of the broadcasting of Russian state channels in the EU.
• Prohibited EU vessels from transporting Russian crude oil from 5th December 2022, and petroleum products from 5th February 2023 to third countries. Also prohibited the related provision of technical assistance, brokering services or financing or financial assistance.
• It is prohibited for operators to broadcast or to enable to be broadcast any content by Russian media outlets RT Arabic and Sputnik Arabic through any means of transmission or distribution, including by cable, satellite, internet or IP-TV. Any broadcasting licence or authorisation, transmission and distribution arrangement with these outlets is to be suspended and it is also prohibited to advertise products in any content produced or broadcast by the outlets mentioned above.
• Export bans on critical technology and industrial goods, such as electronics, machine parts, specialised vehicles, and cranes; further restrictions on the export of dual use goods and advanced technology goods, including 47 new electronic components that can be used in Russian weapons systems; export restrictions on specific rare earth materials and thermal cameras; and further restrictions on imports of goods which generate significant revenues for Russia, such as bitumen and synthetic rubber.
•A ban on non-industrial natural and synthetic diamonds originating or exported from Russia. The ban was introduced on 1st Janury 2024, phased in progressively from March 2024, and completed by September 2024.
Exemptions
1. On 30th November 2017 the EU permitted certain operations concerning hydrazine in concentrations of 70% or more, necessary for the ExoMars 2020 joint mission between the European Space Agency and the Roscosmos State Corporation.
2. On 5th December 2022 the European Council set a price cap of $60 per barrel for the purposes of an exemption to the ban on the provision of maritime transport and related services tied to the sale of Russian seaborne oil to third countries. On 5th February 2023 the European Council adopted new price caps for certain oil products: $100 per barrel for oil products traded at a premium to crude oil, such as diesel, and $45 per barrel for oil products traded at a discount to crude oil, such as fuel oil.
3. An emergency clause was introduced in December 2022 necessary for the prevention or mitigation of an event likely to have a serious impact on human health and safety or the environment, regarding sanctions on Russia’s oil sector.
4. Exemptions to import restrictions are in place on personal use items, including hygiene, clothing, and cars.
On 3rd January 2024 the EU designated PJSC Alrosa and its CEO Pavel Marinychev, Russia’s largest diamond producer, accounting for over 90% of Russian diamond production.
On 12th March 2024, the EU renewed restrictive measures targeting those responsible for undermining or threatening the territorial integrity, sovereignty and independence of Ukraine for another six months, until 15th September 2024.
Sanction Name
Restrictive Measures In Respect Of Actions Undermining Or Threatening Ukraine
SANCTIONS
First Imposed
Last updated
Targets
Asset Freeze and Travel Ban:
• Ukrainian Sovereignty and Security – Those deemed to be responsible for or supporting actions which threaten the security, territorial integrity, sovereignty and independence of Ukraine, or obstruct the work of international organisations there. Also explicitly targets Russian policymakers responsible for the annexation of Crimea and the destabilisation of Eastern Ukraine, or any entities conducting transactions with separatist groups in Ukraine’s Donbass region. The sanctions programme also targets entities in Crimea and Sevastopol which have had their ownership transferred contrary to Ukrainian law and the beneficiaries of such transfers.
• A number of military, political and business figures have been personally sanctioned.
• Export controls and restrictions on the sale of dual-use goods and technology that can contribute to the enhancement of Russia’s defence and security sector, an export ban on aviation and space industry goods, including aircraft engines and their parts, a ban on the direct exports of drone engines to Russia and any third country that can supply drones to Russia, an asset freeze against two additional Russian banks (Credit bank of Moscow and Dalnevostochniy Bank), a full transaction ban on the Russian Regional Development Bank, the suspension of the EU broadcasting licences of four Russian media outlets (NTV/NTV Mir, Rossiya 1, REN TV, and Pervyi Kanal), a ban on the provision of EU advertising, market research and public opinion polling services, a ban on the provision of product testing and technical inspection services to Russia, the prohibition of new investments in Russia’s mining sector (with the exception of certain critical raw material mines and quarries), and a prohibition against EU nationals holding any posts on the governing bodies of any Russian state-owned or controlled legal persons, entities or bodies located in Russia.
Exemptions
1. Exemptions can be granted on a case-by-case basis on humanitarian grounds or for the attendance of inter-governmental meetings.
On 1st February 2024 Switzerland adopted certain measures of the EU’s 12th package of sanctions against Russia, including the ban on Russian diamonds, import controls on various goods, such as iron and LPG, and the ban on Russian nationals from controlling cryptocurrency companies.
Sanction Name
Order Establishing Measures To Prevent The Circumvention Of International Sanctions In Relation To The Situation In Ukraine
SANCTIONS
First Imposed
Last updated
Targets
Asset Freeze:
• Any entities found to be responsible for or complicit in undermining democratic processes or institutions in Ukraine during the country’s ongoing civil conflict, including the assertion of governmental authority over any area of the country without the authorisation of the Government of Ukraine. The assets of the Central Bank of Russia are frozen.
Trade Restrictions:
• Strict controls on investment in Russia and Ukraine, including a prohibition on the provision of loans to companies in Crimea and Sevastopol and on investment in companies and real estate there. The same applies to the so-called Donetsk People’s Republic (“DNR”) and the Luhansk People’s Republic (“LNR”).
• The provision of tourism-related services in the Crimea region is banned and documentation from the Ukrainian authorities is required for the export of goods originating there. Financing relating to the export of goods from Sevastopol and Crimea is prohibited. The same applies to the DNR and LNR.
• There are controls on the issuance of short-term financial instruments to banks and companies in Russia and Ukraine. Financing and finance services to the Russian government and Central Bank of Russia are prohibited.
• Reporting obligations are in place for financial intermediaries and companies providing certain services and technical assistance to listed companies or exporting goods used in prospecting for crude oil in Arctic, deepwater or shale projects.
•On 13th April 2022 SECO announced that it had formally mirrored the latest sanctions package implemented by the EU, the focus of which was a set of new trade restrictions against a number of strategic sectors of the Russian economy, including coal, luxury goods, wood, and cement.
Arms Embargo:
• A ban on the export of dual use and military goods to Russia.
• The importation of military equipment from Russia or Ukraine is banned.
Exemptions
1. There are exemptions for business entered into before the imposition of sanctions in March 2015. Financial instruments with Russian banks which have a maturity exceeding 30 days that were arranged prior to 12th November 2014 are also exempt.
2.SECO may grant exemptions from trade restrictions if goods exported to Crimea and Sevastopol are necessary to prevent serious health or safety hazards, including goods used for the protection of existing infrastructure and the environment.
Sanction Name
Special Designations Certain Persons and Transactions With Respect to the Crimea Region of Ukraine
SANCTIONS
First Imposed
Last updated
Targets
Specially Designated National and Travel Ban:
• Any entities found to be responsible for or complicit in undermining democratic processes or institutions in Ukraine during the country’s ongoing civil conflict, including the assertion of governmental authority over any area of the country without the authorisation of the Government of Ukraine.
• The programme extends to any entities found to have misappropriated assets owned by the government or economically significant entities in the country.
Trade Restrictions:
• US entities are prohibited from any new investment in the Crimea region, from importing goods from Crimea or exporting US goods there, or providing financial support for such transactions. The same applies to the so-called Donetsk People’s Republic (“DNR”) and Luhansk People’s Republic (“LNR”).
• The direct or indirect provision of goods, technology or services, except financial services, in support of oil exploration or production in deepwater or Arctic offshore areas or shale oil production projects in Russian-controlled territory is also prohibited. US entities are prohibited from engaging in the construction of the Nord Stream 2 and Turkstream pipeline projects and are banned from selling or leasing vessels to participate in the projects.
•On 21st February 2022 OFAC released Executive Order 14065, which blocked investment and trading with the so-called Donetsk People’s Republic (“DNR”) and the Luhansk People’s Republic (“LNR”). Any property in the US belonging to or controlled by those deemed to have operated in the DNR or LNR, been a leader of forces in the territory or have materially assisted the territories is subject to sanctions.
Exemptions
1. OFAC authorises certain transactions under 21 General Licences. The majority of these relate to transactions necessary to maintain or wind down operations or existing contracts with several Russian and Ukrainian entities. In addition, certain transactions are authorised if they are deemed necessary to divest or transfer debt, equity or other holdings in certain blocked parties; derivative products whose value is linked to an underlying asset that constitutes a prohibited debt under the sanctions programme; and certain transactions conducted by financial institutions. With regard to Crimea, authorisations extend to: certain transactions related to telecommunications and mail; internet-based communications; the operation of personal accounts; non-commercial personal remittances; and the export or re-export of certain agricultural commodities, medicine, medical supplies and replacement parts.
2. Exemptions include the winding down of transactions involving the DNR and LNR, coronavirus exemptions for the DNR and LNR, some telecommunications and communications exemptions, and exemptions for some remittances and for UN, arbitration and humanitarian organisations.
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Sanction Name
CAATSA Sanctions Against Russia
SANCTIONS
First Imposed
Last updated
Targets
Specially Designated National:
• OFAC can implement CAATSA sanctions against specific parties following a consultation between the Secretary of State, the Secretary of the Treasury and the President. The Secretary of State has drawn up a list of individuals deemed to be senior political figures (Section 241 list) or engaged with the intelligence or defence sectors of the Russian Government, although sanctions have not so far been implemented against them (Section 231 list).
• On 6th April 2018 OFAC sanctioned seven Russian oligarchs and 12 companies they own or control, along with 17 senior Russian government officials, a state-owned Russian weapons trading company and its subsidiary, a Russian bank. These sanctions followed the Treasury’s January 2018 issuance of Section 241 of the CAATSA report to Congress, in which it listed senior Russian political figures and oligarchs, as determined by their proximity to the Russian regime and their estimated wealth.
• CAATSA sanctions are also targeted at parties deemed to be involved in activities of the Russian state that undermine cybersecurity; on persons engaging with the intelligence or defence sectors of the Russian Government; on parties involved in the development of oil pipelines in Russia and those which have invested in Russian state-owned assets. The sanctions also prohibit any transactions in foreign exchange that are subject to US jurisdiction in which the sanctioned party has an interest and also prevent US financial institutions from providing loans totalling $10 million in any 12-month period to sanctioned parties.
On 1st February 2024 the Price Cap Coalition published an Oil Price Cap Compliance and Enforcement Alert, which is directed at both government and industry stakeholders, provides examples of specific evasion methods to improve compliance measures, and provides avenues to report suspected oil price cap breaches to members of the Price Cap Coalition.
On 8th February 2024 OFAC published a determination for prohibitions related to the imports of diamonds of Russian origin and diamonds exports from Russia, as well as a determination for prohibitions related to imports of certain categories of diamonds. On 23rd February 2024 OFAC issued General Licence 83A, authorising certain transactions related to imports of certain categories of fish, seafood, and preparations thereof.
Sanction Name
OFAC Sectoral Sanctions on Russia
SANCTIONS
First Imposed
Last updated
Targets
Trade Restrictions:
• Ban on investment, the transfer of technology and certain transactions to entities within the Russian oil and gas, metals, mining, financial services, engineering and defence industries which are listed on the Sectoral Sanctions Identifiers List.
• Ban on the importation into the United States of crude oil; petroleum; petroleum fuels, oils, and products of their distillation; liquefied natural gas; coal; and coal products of Russian Federation origin.
•Prohibition of imports, exports and new investment in Russian-origin fish, seafood, alcoholic beverages, non-industrial diamonds, luxury goods or any other sector to be determined by the Secretary of the Treasury.
•Prohibition of the provision of quantum computing services to Russian entities and imposition of sanctions on any person or entity determined to operate or have operated in that sector of the Russian economy.
Exemptions
General Licenses 25A, 33 and 34, authorise winddown periods in respect of the export of professional services, including management consultancy and public relations management. General License 25A further permits transactions necessary for the receipt or transmission of telecommunications involving the Russian Federation.
General License 55 authorises certain services related to the maritime transport of crude oil originating from the Sakhalin-2 project, provided that the Sakhalin-2 by-product is solely for importation into Japan. General License 56 authorises certain services related to the importation of crude oil into Bulgaria, Croatia, or landlocked EU member states as described in Council Regulation (EU) 2022/879 on 3rd June 2022. General License 57 authorises certain services related to addressing vessel emergencies concerning the health or safety of the crew or environmental protection.
On 5th December 2022 the Secretary of the Treasury announced that the price cap on crude oil of Russian origin will be $60 per barrel, above which service providers are prohibited from supporting shipments of Russian oil to other countries. On 5th February 2023 OFAC introduced price caps of $45 per barrel for discount to crude oil products and $100 per barrel for premium to crude oil products of Russian origin.
General License 8G, authorises certain transactions related to energy, including transactions involving, among other financial institutions, Russia’s State Corporation Bank for Development and Foreign Economic Affairs and Vnesheconombank.
General Licenses 60 and 61 authorise certain transactions related to the wind down and rejection of transactions, the debt or equity of, or derivative contracts, involving certain entities designated by sanctions imposed on the anniversary of the Russian invasion of Ukraine on 24th February 2023.
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On 8th February 2024 OFAC issued General License 87, authorising limited safety and environmental transactions involving certain designated persons or vessels.
On 23rd February 2024, to mark two years of Russia’s war against Ukraine and in response to the death of opposition politician and anticorruption activist Aleksey Navalny, OFAC sanctioned almost 300 individuals and entities, including targets including the state-owned operator of the Mir National Payment System, NSPK, a major cog in Russia’s financial infrastructure; more than two dozen third-country sanctions evaders in Europe, East Asia, Central Asia, and the Middle East; and hundreds of entities in Russia’s military-industrial base and other key sectors. Together with actions from the US Department of State (“DoS”), this is the largest number of sanctions imposed since Russia’s full-scale invasion of Ukraine. DoS also designated three Government of Russia officials in connection with Navalny’s death; together, OFAC and DoS sanctioned over 500 targets to impose additional costs for Russia’s repression, human rights abuses, and aggression against Ukraine. The Department of Commerce also added more than 90 companies to the Entity List.
OFAC also issued General Licenses 88-90 authorising certain transactions relating to entities and vessels blocked on 23rd February 2024. OFAC issued General Licence 88A authorising the wind down of transactions involving certain entities, General License 89 authorising the wind down and rejection of transactions involving certain financial institutions, and General Licence 90 authorising certain transactions related to debt or equity of, or derivative contracts involving, certain Entities. General Licences 91-93 relate to OFAc’s designation of JSC Sovcomflot, Russia’s state-owned shipping company and fleet operator, which was sanctioned along iwth 14 crude oil tankers as property in which Sovcomflot has an interest, in an attempt to reduce Russia’s revenue from oil sales. Concurrent with the designation of Sovcomflot, OFAC issued General License 92 authorising the offloading of crude oil (or other cargo) from these 14 vessels for a period of 45 days, and General License 93 authorising transactions with all other Sovcomflot-owned vessels at this time. OFAC also issued General Licence 91A authorising limited safety and environmental transactions involving certain blocked persons or vessels. Nothing in these general licenses changes any of the restrictions imposed by the price cap sanctions regime.
On 20th March 2024 OFAC sanctioned two individuals and two entities for services they provided the Government of the Russian Federation in connection with a foreign malign influence campaign, including attempting to impersonate legitimate media outlets.
On 25th March 2024, OFAC sanctioned thirteen entities and two individuals for operating in the financial services and technology sectors of the Russian Federation economy including persons developing or offering services in virtual assets that enable the evasion of U.S. sanctions.
On 2nd April 2024, OFAC deleted three entries linked to VTB Bank Public Joint Stock Company.
On 4th April 2024, OFAC issued two new prohibitions to disrupt the revenue that Russia earns from its export of aluminum, copper, and nickel. This new action prohibits the import of Russian-origin aluminum, copper, and nickel into the United States, and limits the use of Russian-origin aluminum, copper, and nickel on global metal exchanges and in over-the-counter derivatives trading. This action solidifies Treasury’s follow through on the G7 Leaders’ Statement to reduce Russia’s revenues from metals.
On 15th April 2024, OFAC sanctions against Russia under Executive Order 14024 and expanded by Executive Orders 14066, 14039, 14068, 14071, and 14114 were renewed for another year until 15th April 2025.
On 25th April 2024, OFAC sanctioned over one dozen entities, individuals, and vessels that have played a central role in facilitating and financing the clandestine sale of Iranian unmanned aerial vehicles (UAVs) for Iran’s Ministry of Defense and Armed Forces Logistics (MODAFL), which itself is involved in supporting Iran’s Islamic Revolutionary Guard Corps (IRGC) and Russia’s war in Ukraine.
Sanction Name
Russian Harmful Foreign Activities Sanctions
SANCTIONS
First Imposed
Last updated
Targets
Trade Restrictions:
• US nationals are prohibited from transacting with any Russian person or entity deemed by the US Secretary of the Treasury to have been complicit in malicious cyber-enabled activities, interference in a foreign election, to have undermined democratic processes, or to have engaged in transnational corruption or assassination.
• On 16th April 2021 OFAC issued a directive prohibiting US financial institutions from participating in the primary market for new rouble and non-rouble denominated bonds issued by the Russian Central Bank, National Wealth Fund or Ministry of Finance. The directive further prohibits the lending of rouble or non-rouble dominated funds to the same entities. As of later February 2022, there is also a ban on US entities purchasing Russian government debt on the secondary market.
• On 20th August 2021 President Biden signed Executive Order 14039 titled Blocking Property with Respect to Certain Russian Energy Export Pipelines, which targets entities and individuals involved in the construction of the Nord Stream 2 and Turkstream pipeline projects.
• On 22nd February 2022 OFAC amended Directive 1 of Executive Order 14024, imposing new restrictions on US entities dealing in Russian government debt. The measure is aimed at restricting US entities from participating in the secondary market for debt relating to the Russian Central Bank, National Wealth Fund and the Ministry of Finance. On 2nd March 2022, pursuant to EO 14024, OFAC prohibited all transactions involving the Russian Central Bank, the National Wealth Fund and the Ministry of Finance. On 31st March 2022 OFAC extended the trade restrictions outlined in EO 14024 to the aerospace, electronics and marine sectors of the Russian economy.
• In response to the Russian annexations of Donetsk, Luhansk, Kherson and Zaporizhzhia on 30th September 2022, OFAC announced the imposition of further Russian sanctions on 3rd October 2022, pursuant to Executive Order 14024.
Exemptions
1. Transactions with the Federal State Budgetary Institution Marine Rescue Service unrelated to the Nort Stream 2 and Turkstream Pipeline projects. On 23rd February 2022 OFAC released General License 4, which permitted entities involved in transactions with Nord Stream 2 a wind-down period until 2nd March 2022.
2. On 13th April 2022 OFAC issued Russia-related General License No 26, authorising all transactions necessary to the winding down of relationships with JSC SB Sberbank Kazakhstan or Sberbank Europe AG. This was followed on 20th April 2022 by another General License, No 27, authorising “Certain Transactions in Support of Nongovernmental Organizations’ Activities.”
3. On 25th May 2022 OFAC issued Russia-related General License No 13A, authorising certain administrative transactions prohibited by EO 14024. In May OFAC also issued General Licenses 7A, 25A, 26A, 30, 31, 32, 33, 34, and 35, pertaining to a range of sectors including patents, trademarks and copyrights, transactions with Amsterdam Trade Bank NV, trust services, and credit rating agencies.
4. On 28th June 2022 OFAC issued General Licenses 39, 40, 41, 42, and 43 pertaining to transactions with entities such as State Corporation Rostec, PAO Severstal and Nord Gold PLC, as well as transactions with the Federal Security Service and the export to Russia of goods related to civil aviation and agricultural equipment.
5.On 22nd July 2022 OFAC issued General Licenses 44, 45 and 46 pertaining to the export of accounting services to US individuals in Russia, the winding down of certain financial contracts and the authorisation of certain transactions to settle credit derivative transactions.
6.In August 2022 OFAC issued General Licenses 47, 48, 49 and 50 pertaining to the winding down of transactions and contracts involving certain entities blocked by OFAC sanctions, as well as the closure of individual accounts at financial institutions blocked pursuant to sanctions imposed in Executive Order 14024 with respect to specified harmful foreign activities of the Russian government.
7.On 15th September 2022 OFAC issued General License 51 authorising the winding down of transactions involving Russian developer, manufacturer and supplier of computer equipment, limited liability company group of companies Akvarius, or any entity in which Akvarius owns directly or indirectly a 50% or greater interest.
8. On 17th October 2022 OFAC issued General License 28A, authorising certain transactions involving OOO Transkapitalbank and Afghanistan.
9. In November 2022 OFAC issued General Licenses 8D, 53, and 13C, authorising certain transactions prohibited by Executive Order 14024, such as administrative transactions and transactions for diplomatic missions. OFAC also issued General Licenses 40C and 54, authorising transactions necessary for civil aviation safety and certain transactions related to VEON Ltd. On 22nd November OFAC issued General Licenses 55, 56, and 57, authorising certain transactions related to the newly introduced oil price cap, such as transactions concerning emergencies to the health and safety of the crew or environmental protection.
10. On 15th December 2022 OFAC issued General Licenses 58 and 59, authorising certain transactions involving the divestment or transfer of debt or equity from, and the wind down and rejection of transactions involving PJSC Rosbank.
11. On 19th May 2023 OFAC issued General License 13E authorising certain administrative transactions, General License 66 authorising the wind down of trasnactions involving PJSC Plyus, General License 67 authorising certain transactions related to debt or equity of, or derivative contracts involving, PJSC Polyus, and General License 68, authorising the wind down of transactions involving certain universities and institutes.
12. On 31st May 2023 OFAC issued General License 69 authorising certain debt securities servicing transactions involving the International Investment Bank.
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On 15th December 2023 the UK introduced the Russia (Sanctions) (EU Exit) (Amendment) (No. 4) Regulations 2023 which bans the import of certain Russian metals; expands the payments processing restrictions to include non-sterling payments; prohibits the provision of technical assistance relating to luxury goods; provides statutory footing for annual frozen assets reporting to OFSI and imposed reporting obligations for designated persons; and included a licensing ground for divestment. Later that day the UK designated JSC Bank Novikombank, prohibiting correspondent banking relationships with the bank, imposing an asset freeze, and trusts services sanctions. A General Licence was issued allowing for the processing of payments for winding down with Novikombank.
On 23rd February 2024 OFSI sanctioned over 50 new individuals and entities sustaining Russia’s war in Ukraine, marking two years since the invasion. Sanctions targeted those supplying Russia’s depleted armoury with munitions such as rocket launch systems, missiles and explosives, as well as key sources of Russian revenue, clamping down on metals, diamonds, and energy trade.
Sanction Name
Russia (Sanctions) (EU Exit) Regulations 2019
SANCTIONS
First Imposed
Last updated
Targets
Arms Embargo, Trade Restrictions and Travel Ban:
• Prohibition on the provision of long-term financial or investment services to state-owned Russian financial institutions, the export of arms and related materiel and on the supply of dual-use goods and technology to military end-users, as well as services, goods and technology related to deep water, Arctic and shale oil prospecting. The procurement from Russia of arms and related materiel is prohibited, and there is also a ban on trading in certain bonds, equities, and securities, as well as the provision of trust services, and other financial instruments.
•Designation of anyone either involved in destabilising Ukraine or undermining or threatening its territorial integrity, sovereignty or independence; or obtaining a benefit from or supporting the Government of Russia. Any trade relating to the so-called Donetsk People’s Republic (“DNR”) and Luhansk People’s Republic (“LNR”) are prohibited.
•Ban on Russian companies participating in UK capital markets and a ban on the Russian state raising sovereign debt in the UK.
• Prohibitions on the export of hi-tech and strategic industries. Russian nationals are only permitted to hold a maximum of £50,000 in one bank account. The UK also imposed sanctions on Minister of Foreign Affairs Sergey Lavrov and on President Putin on 25th February 2022.
•Prohibition of access to UK ports by Russian ships and other ships specified by the Secretary of State, as well as the provision of financial services to the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation.
•On 9th March 2022 OFSI further amended its Russian sanctions program, conferring on the Secretary of State the power to detain any aircraft overflying or landing in the UK that is “connected with Russia”.
•Ban on the export of high-end luxury goods to Russia.
• Prohibition of the provision of professional services to persons connected with Russia, including Russian residents temporarily located in another country, prohibiting the importation, acquisition, supply or delivery of Russian-origin gold, banning the export of energy-related goods to Russia, regardless of the eventual point of use, and also prohibiting the making available of energy-related goods to any persons connected with Russia.
• In response to the sham referenda and subsequent Russian annexation of Donetsk, Luhansk, Kherson and Zaporizhzhia, the UK introduced services export bans on IT consultancy, architectural services, engineering services, advertising services, auditing services, and transactional legal advisory services.
• Prohibition of the export, supply and delivery of goods for use in Russia that are deemed to be critical to the functioning of Russia’s economy. The prohibited goods are compiled in the Russia Vulnerable Goods list. The amendment also prohibits the import of certain other revenue generating goods, including but not limited to beverages, spirits, food waste products, and gold. A prohibition on the importation of Liquefied Natural Gas which is consigned from or originates in Russia came into force on 1st January 2023.
• Ban on the import of both Russian oil and oil products, in line with the other G7 governments. OFSI also banned the maritime transportation of Russian oil from 5th December 2022 and refined oil from 5th February 2023. The ban applies to the maritime transportation of the oil and oil products from a place in Russia to a third country, or from one third country to another third country. Similarly OFSI banned the associated services which facilitate this maritime transportation.
•Ban on the direct and indirect provision of auditing, advertising, architectural, engineering, and IT consultancy and design services to persons connected with Russia.
Exemptions
• In October 2022 OFSI issued two General Licenses under the Russia and Belarus sanctions regimes. The first indefinitely authorises designated people or entities to pay funds to the London Court of International Arbitration to cover arbitration costs, and the second authorises until 28th April 2023 the payment of legal fees by designated people and entities to law firms and counsel.
• On 2nd November 2022 OFSI published General Licence INT/2022/2339452, authorising Truphone Limited to provide telecommunication services, to pay remuneration, allowances and pensions, to pay fees and third-party providers necessary for the functioning of the business, and to make and receive payments due under contractual obligations. On 11th November 2022 OFSI amended the General Licence to add subsidiary companies of Truphone Limited and extend the licence expiry date until 28th April 2023.
• On 4th November 2022 OFSI issued General Licence INT/2022/2349952, which authorises certain transactions related to agricultural commodities, including the provision of insurance and other services.
• From 10th November 2022 until 10th November 2023 General Licence INT/2022/1919908 authorises non-designated persons to make use of the retail banking services of Credit or Financial Institutions designated under the UK’s Russia sanctions regime, provided that the payments are intended for the non-designated person’s personal use, and the total value of payments made by the non-designated person does not exceed £50,000
• On 5th December 2022 OFSI introduced a coordinated Oil Price Cap exception to the maritime transportation and associated services ban, making UK services available to third country importers and exporters, so long as the price paid for Russian oil or oil products is at or below the agreed price cap of $60 per barrel.
• On 16th February 2023 OFSI amended General Licence INT/2022/1839676 on Russian Travel to allow UK nationals or entities to purchase tickets from South Caucasus Railway CJSC for passenger rail journeys between Armenia and Georgia and within these countries. The General Licence will expire on 23rd May 2024.
• General License INT/2023/3024200 on Prior Obligations, permitting a UK person who is owed funds by a designated person under the Russia and Belarus sanctions programmes to receive payment, provided that the contractual obligation was signed before the person’s designation, the payment is for the benefit of a UK person, the value of the payments does not exceed £200,000, the designated person’s banks are permitted to transfer funds for this purpose, and no other UK person can use the General Licence to receive funds from the same contractual obligation. Certain contracts are not applicable under the General Licence, including professional legal fees, bonds, derivatives, and credit default swaps. The General License is effective from 22nd May 2023 and expires on 21st November 2023.
• General Licence INT/2023/3074680 permitting the trade in oil derivatives and futures previously prevented. The exemptions apply to individuals, organisations and brokers trading in derivatives and futures based on Russian oil, as well as institutions processing payments in relation to these activities.
• General Licence INT/2023/3263556 allowed payments and other actions to take place in relation to insolvency proceedings associated with GTLK, Russia’s largest state transport leasing company, the related Irish companies GTLK Europe DAC and GTLK Europe Capital DAC and their subsidiaries. GTLK Europe DAC and GTLK Europe Capital DAC were wound up by the Irish High Court on 31st May 2023.
• General License INT/2024/4398024 allowed payment of monies owed to designated persons into any Civil court pursuant to a Court Order.
• General License INT/2024/4671884 allowed payment of monies owed by designated persons to law firms in the case of prior obligation.
