EU/UK (potential) sanctions against Russia (23-02-2022)
Written By
Senior Counsel
Netherlands
I am a Senior Counsel focusing on compliance with anti-bribery, customs, export controls and economic sanctions regulations.
Senior Associate
Netherlands
As a senior associate in our Trade & Customs Group in The Hague and Brussels, I am an international trade and customs lawyer focusing on a broad spectrum of trading matters on behalf of our multinational and national clients.
Partner
Netherlands
As co-head of our International Trade & Customs Group I have in-depth, long-standing experience in the full range of customs and trade related matters, sanctions regimes and the application of EU export controls. Whilst working across Europe I am based in The Hague.
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Considering the current situation in Ukraine, several parties – including the European (“EU”) Union and the United Kingdom (“UK”) have announced sanctions that will or could be imposed against Russia.
Even though the situation in Ukraine continuously evolves and may be subject to immediate changes, the imposed, announced and potential EU and/or UK sanctions are listed below – depending on particular scenarios:
1. Recognition by Russia of Donetsk and Luhansk as independent states and the deployment of Russian forces in Donetsk and Luhansk
| EU/UK sanctions against Russia | Description |
| List-based blocking/freezing measures and orders of EU and UK sanctioned entities and individuals | These measures involve asset blocking measures, such as an asset freeze or a prohibition on making economic funds or resources available to various EU and UK sanctions individuals and entities from Russia |
| Ban on trade and investment with Donetsk and Luhansk Regions | Prohibition to: - import goods from these regions; - export goods and certain technology to these regions; - trade or invest in certain sectors in these regions; - supply tourism services in these regions |
| Adjust EU-Ukraine FTA | Removal of Donetsk and Luhansk Regions from EU-Ukraine free-trade deal |
| Additional financial sector sectoral sanctions | With the purpose to limit the ability of the Russian state and government to access EU capital and financial markets and services |
2. Deployment of military forces in Ukraine by Russia beyond Donetsk, Luhansk and Crimea
| Possible EU/UK sanctions against Russia | Description |
| List-based blocking/freezing measures and orders of EU and UK sanctioned entities and individuals | These measures involve asset blocking measures, such as an asset freeze or a prohibition on making economic funds or resources available to various EU and UK sanctions individuals and entities from Russia. |
| Adding sanctioned entities and individuals from or connected to Russia | Additional sanctioned entities and individuals, especially from the financial, energy, defence or technology sectors of Russia, might be added to the current EU and UK sanctions listings. |
| SWIFT (Society for Worldwide Interbank Financial Telecommunication, which handles international transfers) | Financial related restrictive measures can be expected with regard to Russian financial and banking institutions. One of the most aggressive measures being discussed involves banning Russia from the use of SWIFT. |
| Increase of export controls related restrictions | The restrictions regarding export of dual-use items might be further amended by prohibiting the export of certain technology vital (“cutting-edge” technology such as semiconductors) to certain specific Russian sectors as well as increasing the scope and range of restricted end users in Russia or related/connected to Russia. |
| Nord Stream 2 pipeline | Restrictions regarding the use of Nord Stream 2 pipeline as well as any additional energy sector focused trade restrictions including a limitation of investments in the Russian oil and gas sector. For the sake of completeness, we note that the project is halted in order to be certified. |
3. Deployment of military forces in Ukraine by Russia beyond Donetsk, Luhansk and Crimea, with the assistance/cooperation of Belarus
| Possible EU/UK sanctions against Belarus | Description |
| All of the above or similar as potentially to be imposed against Russia | Russian forces are stationed in Belarus. In the event of an invasion to Ukraine (and/or its capital Kyiv) from Belarus, it was announced that this country could face the same sanctions as Russia. |
Bird & Bird’s Trade & Customs Team is happy to assist your business with sanctions queries related to the above or otherwise.
For general sanctions compliance and to seek assurance that your (potential) business partner does not appear on a sanctions list, you are invited to check our sanctions screening app which is available in the Apple and Google app stores and through a web-based app.
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