This month, changes to the main Western sanctions programs have continued to focus on undermining strategic sectors of the Russian economy via the imposition of trade restrictions, as well the designation of multiple of senior military figures and those within Putin’s circle deemed to have facilitated the ongoing crisis.  Significant new measures have included:

 

  • On 4th May UK Foreign Secretary Liz Truss announced a ban on service exports to Russia, covering management consultancy, accounting and public relations. The announcement was accompanied by the designations of 31 people and 32 entities, the vast majority of which were drawn from Russia’s state-owned media outfits, as well as steel manufacturing and mining company Evraz.  On 12th May the UK designated 12 people said to be part of President Putin’s personal and financial “inner circle”, and on 19th May sanctioned three Russian airlines – Aeroflot, Ural Airlines, Rossiya Airlines.

 

  • Also on 4th May the EU announced its 6th sanctions package, comprising principally a ban on the importation of Russian oil, the designations of several high-ranking military officers deemed responsible for war crimes in Bucha and the siege of Mariupol, as well as the removal of Sberbank and two other banks from the SWIFT network. The importation of Russian crude into EU companies will be phased out within 6 months and the importation of refined products by the end of 2022.  The announcement was followed by a G7-wide press release issued on 9th May in which each G7 country committed to phasing out Russian oil.

 

  • On 8th May OFAC announced a raft of designations including eight current and former Sberbank executives, 27 Gazprom executives and Russian state-controlled television stations, as well as shipping and maritime engineering companies. OFAC has also released several General Licenses authorising transactions with Gazprom’s operations in Germany, certain internet-based communications, and several relating to the wind down of transactions with recently sanctioned entities, notably of the export to Russia of accounting and management consulting services.

 

  • In non-Russia related news, the UN Security Council met on 11th May to discuss new sanctions on North Korea and the extension of the non-proliferation programme. Representatives from Japan, France, the UK and the US reportedly called for the UN’s North Korea sanctions regime to be updated, while representatives of Russia and China cautioned against the use of sanctions and their unintended humanitarian consequences.

 

  • On May 23rd 2022 the UN Special Rapporteur completed a 12-day trip to Iran and, upon her return, published preliminary findings detailing how unliteral sanctions against Iran, secondary sanctions and the threat of sanctions had substantially exacerbated the humanitarian situation in the country, including in relation to access to medicine and healthcare.

 

  • Non-Russia related designations have included OFAC’s sanctioning of the Guatemalan Attorney General on 18th May, due to her alleged role in “significant corruption”, as well as networks of alleged Hizballah, IRGC and ISIS financiers.

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