Ukraine Crisis: “Third Round” of US, EU, and UK Sanctions and Export Controls on Russia are Broader and More Severe

The United States, EU, and UK continue to impose new sanctions and export control restrictions related to Russia, in response to the crisis in Ukraine.  This “third round” of escalating measures are a significant increase in the scope and severity of the response to Russia, cut across a wide range of economic sectors, and reflect continued multilateral coordination.  Our prior client briefings discuss the first round and second round of new sanctions on Russia.  Additionally, Russia has started implementing various countermeasures targeting foreign currency transactions but stopping far short of full countersanctions.

The key takeaways are:

Ban on Russian energy imports: On March 8, 2022, the United States banned imports of Russian oil, liquefied natural gas, and coal into the United States, as well as new investment in the Russian energy sector. The UK will phase out imports of Russian oil by the end of 2022, and the EU plans to reduce imports of Russian gas by two-thirds this year.

Removal from SWIFT: As of March 12, 2022, SWIFT (the main network through which international payments are initiated between banks) will remove seven Russian financial institutions from its network, as agreed between the United States, EU, UK, and Canada: Bank Otkritie, Novikombank, Promsvyazbank, Rossiya Bank, Sovcombank, Vnesheconombank (VEB), and VTB Bank.

Additional financial sector restrictions: 

• Asset freezes:  The UK imposed asset freezes on additional banks, including VEB, Bank Otkritie, Sovocombank, and the Russian Direct Investment Fund (RDIF). 
• Sanctions on the Central Bank of Russia (CBR):  The United States, EU, and UK imposed restrictive measures on the CBR that target a wide range of dealings, with differing limitations, exceptions, and general licensing
• Restricting new debt and equity:  The EU and UK imposed additional prohibitions on dealings in new debt and new equity of number of Russian banks and companies.  This includes bans on (i) selling Euro-denominated securities to Russian nationals and entities; (ii) listing or providing services on EU trading venues of Russian state-controlled entities; (iii) EU financial institutions from accepting deposits from Russian nationals or entities of more than EUR 100,000 and central securities depositories from providing services to Russian nationals or entities; and (iv) EU and UK provision of new loans to a range of Russian entities and banks.

Export controls: Russia-related export controls have significantly increased across the United States, EU, and UK, with a broad range of goods, technology and software now restricted or requiring a license for export to Russia.

• The United States imposed export controls on Belarus that almost entirely match the new export controls imposed on Russia on February 24, 2022.  The United States also increased export control restrictions on oil and gas extraction equipment that supports Russia’s refining capacity and added an additional 91 parties to the Entity List for involvement in or support of Russian security, military, or defense activities. 
• The EU imposed a ban on exports of dual-use goods and technology; technological and certain other goods; goods relevant for the aviation and space industries, including aircrafts; and goods and technologies used in oil refining, all for use in Russia.
• The UK prohibited exports of dual-use goods and a wide range of goods and technology not previously subject to UK export controls, such as telecommunications and computing hardware and technology.  Although the legislation permits applications for license, guidance suggests that applications are unlikely to be granted absent exceptional circumstances.
• The restrictions in the EU and UK differ in many respects but both export control programs also cover ancillary services, such as technical assistance, brokering services or financing or financial assistance.

Designations of Putin, government officials, and oligarchs: The United States, EU, and UK added President Vladimir Putin and a number of high-ranking Russian officials and oligarchs to their sanctions lists, and the EU is considering a new package of sanctions that would ban three Belarussian banks from SWIFT, designate several more Russian oligarchs and politicians, and ban naval equipment and software exports. 

Additional announcements: The UK is debating the introduction of strict liability penalties for civil breaches of the sanctions regime and has imposed sanctions targeting insurance and reinsurance in the aviation and space sectors.

Russian countermeasures: Russia has adopted three decrees to counter the economic effects of the sanctions: the decrees essentially impose currency restrictions that are designed to severely limit the capacity of Russian residents (citizens and legal entities) to transact in foreign currency.  Additionally, an addendum allows – and in some instances requires – repayment in rubles of certain obligations denominated foreign currency, based on a list of “unfriendly states.”  These measures are creating challenges for companies looking to exit investments in Russia, in addition to Russia’s “fake news” law.

SWIFT ban to target certain Russian banks

On February 26, 2022, the United States, the European Commission, France, Germany, Italy, the United Kingdom and Canada issued a statement committing to removing selected Russian banks from the SWIFT messaging system.  Japan agreed to the Joint Statement the next day.  On March 2, the European Union decided that Bank Otkritie, Novikombank, Promsvyazbank, Rossiya Bank, Sovcombank, VEB, VTB Bank, and their subsidiaries, will be removed from SWIFT on March 12, 2022 and therefore disconnected from the messaging network that connects thousands of financial institutions around the world.

United States bans energy imports, new energy investment, designates President Putin, restricts dealings with the Central Bank of Russia, and increases export controls against Russia’s oil refinery sector and Belarus

Restrictions on oil and gas imports and new investment in the energy sector 

On March 8, 2022, President Biden issued an Executive Order (EO) prohibiting the importation into the United States of Russian-origin crude oil, petroleum, liquefied natural gas, and coal; new investment in the energy sector in Russia by US persons; and any approval, financing, or facilitation of a non-US person of such activities.  OFAC simultaneously issued General License 16, which authorizes, until April 22, 2022, transactions ordinarily incident and necessary to imports of these products pursuant to agreements entered into prior to March 8, 2022.

OFAC defines “new investment” in this context as “a transaction that constitutes a commitment or contribution of funds or other assets for, or a loan or other extension of credit to, new energy sector activities (not including maintenance or repair) located or occurring in the Russian Federation beginning on or after March 8, 2022.”

Restrictions on the Central Bank of Russia

On February 28, 2022, OFAC issued Directive 4 under EO 14024, which prohibits US persons from engaging in transactions, including the transfer of assets or any foreign exchange transaction, involving the Central Bank of the Russian Federation or CBR, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation (the Directive 4 entities).  OFAC issued additional guidance related to Directive 4 on March 2, 2022, emphasizing the need to ensure that Russia does not have the ability to exploit loopholes to evade sanctions. 

OFAC general licenses authorize specified activities related to the Directive 4 entities, including certain activities related to energy (General License 8A, until June 24), note-related payments (General License 9A, until May 25), wind-down of certain derivative-related agreements (General License 10A, until May 25), administrative transactions that include tax payments, licensing, and registration (General License 13, until June 24), and certain clearing and settlement (General License 14).  General License 13 (GL13) appears likely to have the greatest impact on companies doing business in Russia that are required, for example, to make payroll tax payments.  Continued business in Russia may become significantly more challenging if GL13 expires and is not renewed beyond June 24, 2022.

Additional designations (since February 24): politicians, financial institutions, companies, oligarchs, disinformation outlets, and defense-related firms

In a series of recent actions, OFAC added a number of Russian officials, government entities, elites, companies, and media outlets to the US List of Specially Designated Nationals (SDN list).

• On February 25, 2022, OFAC added to the SDN list several high-ranking Russian officials, including Russian President Vladimir Putin and Minister of Foreign Affairs Sergei Lavrov.
• On February 28, 2022, OFAC added to the SDN list three entities that help manage Russia’s key sovereign wealth funds under EO 14024: RDIF, Joint Stock Company Management Company of the Russian Direct Investment Fund (JSC RDIF), and Limited Liability Company RVC Management Company (LLC RVC).  OFAC also designated Kirill Aleksandrovich Dmitriev, CEO of RDIF and JSC RDIF.
• On March 3, 2022, OFAC added to the SDN list three Russian elites – Alisher Usmanov, Nikolay Tokarev, and Yevgeniy Prigozhin – for providing resources and support to the Russian Government.  OFAC also designated five of their family members, six of their companies, one of Russia’s largest privately-owned aircraft, and one of the largest superyachts in the world.  Along with these designations, OFAC issued General License 15, which indefinitely authorizes transactions involving entities owned 50 percent or more by Usmanov that have not been separately added to the SDN list.
• Also on March 3, 2022, OFAC added to the SDN list a number of individuals and entities in connection with the Russian government’s efforts to promulgate disinformation and influence perceptions.  In a coordinated action, the US Department of State sanctioned 22 Russian defense-related firms.

Export controls targeting Belarus now largely match those targeting Russia

On March 2, 2022, the US Commerce Department’s Bureau of Industry and Security (BIS) imposed on Belarus most of the sweeping new export controls under the US Export Administration Regulations (EAR) that were imposed on Russia on February 24, 2022.  Among the restrictions are two new Foreign Direct Product rules, a near total ban on exports of items to both Russian and Belarusian military end users, and a policy of denial for the export of controlled items that support Belarus’s defense, aerospace, and maritime industries. 

BIS also added two entities – JSC Integral and The Ministry of Defense of the Republic of Belarus (which encompasses the national armed services, including the army, navy, marine, air force, or coast guard; national guard and police; and government intelligence or reconnaissance organizations of Belarus) – to the Entity List.  This action creates a licensing requirement (subject to a policy of denial) for the export, reexport, or transfer (in-country) of all items subject to the EAR to those entities, with limited exceptions.

See our “second round” of new Russia sanctions client briefing for more information on the export controls imposed on Russia on February 24.

Additional export controls targeting Russia’s oil refinery sector and new Entity List designations related to security, military, and defense actors

On March 3, 2022, BIS announced additional sector-specific export controls targeting the Russian oil refinery sector.  The new restrictions build on existing Russian industry sector export controls, and impose a licensing requirement for exports, reexports, and transfers (in-country) to and within Russia of certain critical oil refining equipment that is subject to the EAR.  Importantly, unlike existing sector restrictions targeting Russia, the new controls do not include a requirement that the exporter have knowledge or reason to know that the item to be exported will be used in Russia’s energy sector. 

Also on March 3, 2022, BIS added 91 new entities to the Entity List in response to Russia’s destabilizing conduct in Ukraine.  According to BIS, the designated entities – located in Belize, Estonia, Kazakhstan, Latvia, Malta, Russia, Singapore, Slovakia, Spain, and the United Kingdom – have been involved in, contributed to, or supported Russian security services, military and defense sectors, and military and defense research and development efforts.  As a result of this action, a licensing requirement (subject to a policy of denial) applies to the export, reexport, or transfer (in-country) of all items subject to the EAR to the listed entities, with limited exceptions.

EU designates President Putin and oligarchs, imposes financial services and capital market restrictions, and further escalates export control restrictions

Additional designations (since 24 February): politicians, energy, and individuals related to various sectors

On February 25, 2022, the EU imposed asset freezes on Russian President Putin and Foreign Minister Sergey Lavrov.  In addition, the EU also sanctioned the members of the Russian National Security Council who supported Russia’s recognition of the so-called Donetsk People’s Republic and Luhansk People’s Republic regions of Ukraine, the remaining members of the Russian State Duma, and Belarusian individuals that facilitated Russia’s invasion of Ukraine.

On February 28, 2022, the EU imposed a further round of asset freeze measures directed against Gas Industry Insurance Company SOGAZ and a number of individuals, including military officials, government members, journalists, and the following oligarchs involved in the oil, banking and finance sectors: Igor Sechin, Nikolay Tokarev, Alisher Usmanov, Petr Aven, Alexander Ponomarenko, Mikhail Fridman, Sergei Roldugin, Gennady Timchenko and Alexey Mordashov.

Financial services sector and capital market restrictions

On February 25, 2022, February 28, 2022, and on March 1, 2022, the EU imposed the following additional financial services and capital markets sanctions:

• Prohibitions on dealings in new debt and equity: The EU now prohibits dealings in new equity (dealings involving “transferable securities” and “money-market instruments”) of (i) additional Russian banks, including Alfa Bank, Bank Otkritie, Bank Rossiya and Promsvyazbank (the latter two banks are also subject to asset freeze measures); and (ii) eight Russian state-owned entities, including Almaz-Antey, Kamaz, Novorossiysk Commercial Sea Port, Rostec, Russian Railways, JSC PO Sevmash, Sovcomflot, and United Shipbuilding Corporation. The provision of new loans to these entities is also prohibited.  
• Listing restrictions: The EU also issued a prohibition on listing or providing services via EU trading venues in connection with transferable securities of Russian entities with over 50 percent public ownership.
• Ban on deposits over EUR 100,000: EU banks are prohibited from accepting deposits from Russian persons (excluding EU nationals and EU residents) over EUR 100,000. EU banks and financial institutions are also subject to new reporting requirements related to Russian person deposits of greater than EUR 100,000.
• Prohibition on the selling of EUR-denominated securities: The EU also imposed a ban on the sale to Russian persons of EUR-denominated securities issued after April 12, 2022 and certain investment instruments providing exposure to such securities.
• Prohibition on the provision of public financing or financial assistance: The EU issued a prohibition on the provision of public financing or financial assistance for trade with, or investment in, Russia.
• Ban on transactions with the Russian Central Bank: The EU imposed a ban on financial management activities related to the reserves and assets of the Central Bank of the Russian Federation, as well as a prohibition on all direct and indirect transactions with the Central Bank of Russia.
• Ban on supply of EUR-denominated banknotes to Russia: New EU restrictions prohibit the sale, transfer, or export of EUR-denominated banknotes to any individual or entity located in Russia, including the Russian Government and the Russian Central Bank, or for use in Russia, with limited exceptions.
• Prohibitions on projects financed by the Russian Direct Investment Fund: The EU also issued a prohibition on any investment in, participation in, or contribution to future projects financed by RDIF.

Export control restrictions on dual-use, military, energy, aviation, and space items

• Dual-use goods and technology: New EU export controls restrict the export to Russia of any dual-use goods, technology or technical assistance without a license.  This is a broad expansion of EU export controls, which previously restricted only exports to Russia that were intended for a military use or military end-user.  The new restrictions have limited exceptions, and licenses may be granted for certain exports not intended for a military use or a military end-user if they are related to a contract entered into prior to February 26, 2022.  Such license applications must be submitted by May 1, 2022.
• Technology items: The EU also imposed controls on goods and technology that “might contribute to Russia’s military and technological enhancement, or the development of the defense and security sector.”  The relevant items are listed in a new Annex VII to Regulation (EU) 833/2014 across the following categories: electronics, computers, telecommunication items, information security, sensors, lasers, navigation, avionics, marine, and aerospace and population items. Similar to the dual-use restrictions, it is generally prohibited to export any listed item to Russia or for use in Russia without a license, with limited exceptions. Licenses for the performance of pre-existing contracts may be available if the authorization is requested before May 1, 2022.
• Certain energy goods: The EU now prohibits the export to Russia of goods and technology for use in the oil refinery sector, as well as the provision of related technical assistance, brokering services, or financing.  The prohibition includes an exemption until May 27, 2022 for the execution of contracts concluded before February 26, 2022.
• Aviation and space goods: The EU now prohibits the export to Russia of goods and technology for use in aviation or the space industry (including aircraft, spacecraft, and related parts), as well as the provision of related technical assistance, brokering services, or financing.  EU controls further restrict services to overhaul, repair, inspect, replace, or modify an aircraft or aircraft component, with the exception of pre-flight inspection services.  The restriction provides for a limited exemption for certain activities until March 28, 2022, for the execution of contracts concluded before February 26, 2022.

Additional EU restrictions on travel and broadcasting

Under new EU restrictions, Russian diplomats, officials, and businesspersons will no longer be permitted to benefit from EU visa facilitation provisions.  The EU also introduced a prohibition on Russian aircraft overflight of EU airspace and access to EU airports, as well as a ban in the EU on broadcasting activities by Sputnik and Russia Today (RT).

UK designations and amended Russia Regulations aim to close financial markets and restrict exports to Russia

Additional designations (since February 24): officials and financial institutions 

The UK has added President Putin and other Russian government officials and military leaders to the UK sanctions list, as well as a number of Russian financial institutions:  VEB, Bank Otkritie, Sovocombank and RDIF.  More designations of Russian banks are expected to follow. 

New restrictions on banking, investment, securities, debt, and financial services

The Russia (Sanctions) (EU Exit) (Amendment) (No. 2) Regulations 2022, published on March 1, 2022, imposes the following new financial and investment restrictions relating to Russian financial institutions and the Russian government, which are expected to have a significant impact on Russia-related financial transactions:

• Prohibition on correspondent banking and sterling transactions (Sberbank): New Regulation 17A prohibits UK credit or financial institutions from: (i) establishing or continuing a correspondent banking relationship with a 17A designated person, regardless of the currency of the account (subject to a 30-day wind-down general license); or (ii) processing (which includes clearing and settling) payments in sterling to, from or via a 17A designated person, as well as with credit or financial institutions owned or controlled by a 17A designated person, subject to a 30-day wind-down general license and a further general license until June 24, 2022 in respect to payments related to relevant energy products.
• Expanded restrictions on dealing in new Russian securities and new debt: The new legislation prohibits dealing in new (post-March 1) securities and money market instruments, or extending new loans or credit, by (i) the UK subsidiaries of previously-sectorally sanctioned entities (Sberbank, VTB Bank, Gazprombank, VEB, Rosselkhozbank, OPK Oboronprom, United Aircraft Corporation, Uralvagonzavod, Rosneft, Transneft and Gazprom Neft); the Government of Russia, defined to include (among others) any Ministry of the Russian Federation, the Central Bank of the Russian Federation and any other public body or agency of the Government of the Russian Federation; and (iii) all entities domiciled in Russia that are not subsidiaries of companies domiciled outside of Russia, with a wind-down general license until March 8, 2022 and no specific licenses available.
• Expanded restrictions on issuing new Russian debt: Amended Regulation 17 prohibits the grant of loans or credit with a maturity exceeding 30 days to: (i) the previously sectorally sanctioned entities (as listed above) and their non-UK subsidiaries, if the loan was first granted after December 31, 2020; (ii) the UK subsidiaries of the previously sectorally sanctioned entities (as listed above), if granted after March 1, 2022; (iii) the Government of Russia, if granted after March 1, 2022 (regardless of maturity); and (iv) an entity connected with Russia (or to an entity owned by them/acting on their behalf), first made on or after March 1, 2022. For the latter category, a person connected with Russia is any entity incorporated or domiciled in Russia (or owned by such an entity), but loans granted to entities domiciled in a country other than Russia or owned by such an entity are excluded from this category and are not prohibited unless they fall into one of the other categories above. There is an exemption available for certain drawdowns, subject to conditions relating to the date on which the arrangements were entered into and the terms were agreed, whether the terms have since been amended, and the fixing of the contractual maturity date. A general license is also available until March 8, 2022.
• New prohibition on providing financial services to the Central Bank of Russia: The Russia (Sanctions) (EU Exit) (Amendment) (No. 5) Regulations 2022 prohibits providing a broad range of financial services to the CBR and related institutions.  Under new Regulation 18A, providing financial services for the purpose of foreign exchange reserve and asset management to the CBR, the Russian National Wealth Fund, the Ministry of Finance of the Russian Federation, a person owned or controlled directly or indirectly by these entities (which definition includes Sberbank), or a person acting on behalf of or at the direction of these entities, is prohibited. No wind-down general license is available save in respect of PJSC Sberbank until April 3, 2022.

OFSI has also issued three general licenses to permit certain transactions in order to wind down business with VTB or its subsidiaries until March 27, 2022; for VTB to make certain types of payments until March 1, 2023; and to authorize relevant financial authorities to take steps with respect to VTB’s UK subsidiaries to protect the financial stability of the UK until March 1, 2023. OFSI has also issued a further general license to permit certain transactions in order to wind down business with Bank Otkritie, Promsvyazbank, Bank Rossiya, Sovcombank, VEB and Novikombank (and their subsidiaries) until April 3, 2022.

Export control restrictions on Russia related to commercial goods and energy items

The UK has also taken steps to significantly expand restrictions on commercial trade with Russia:

• Greater range of goods and technology now subject to export licensing requirements: The Russia (Sanctions) (EU Exit) (Amendment) (No. 3) Regulations 2022 (the Regulations) extends, in relation to Russia, the restrictive export controls regime that previously applied only to military goods to all goods and technology classified as “Restricted Goods and Restricted Technology.”  This new category includes: (i) all goods and technology previously classified for military use; (ii) all goods and technology previously classified as dual-use; and (iii) a wide variety of new goods and technology not previously subject to trade controls in relation to Russia, including electronic hardware and software from computers, telecoms equipment, information security systems to sensors, lasers and some marine, aerospace and navigation devices (Critical Industry Goods and Critical Industry Technology).
• Without a license (subject to a general policy of denial), all Restricted Goods and Restricted Technology are prohibited from being exported from the UK to, or for use in, Russia; supplied or delivered from a third country to Russia; made available to a “person connected with Russia”; acquired from a “person connected with Russia”, and/or transferred to Russia or a “person connected with Russia” or from Russia to a person or place outside the UK.
• Providing technical assistance, financial services and/or brokering services related to the provision or making available of Restricted Goods and Services relating to Russia can be prohibited in some circumstances.
• Licensing changes to energy-related export controls regime: On March 1, 2022, the UK Department of International Trade (i) suspended all current licenses and the approval of new licenses for the export of dual-use items to Russia; and (ii) removed Russia as a permitted destination from nine open general export license (OGELs), covering specified products including certain chemicals, cryptographic items and oil and gas exploration items. Exporters who previously relied on the OGELs will now need to apply to the Export Control Joint Unit (ECJU) for standard individual export licenses (SIELs) and await approval before exporting goods to Russia.  

New sanctions on shipping; insurance related to aviation and space

The Russia (Sanctions) (EU Exit) (Amendment) (No. 4) Regulations 2022, enacted on March 1, 2022, effectively bars Russian ships from UK ports.  It is now an offence for anyone to permit a ship access to a port in the UK if that person knows or has reasonable grounds to suspect that the ship: is owned, controlled, chartered or operated by a designated person or by persons domiciled or incorporated in Russia; is flying the Russian flag; or is registered in Russia.

On March 8, 2022, the UK imposed sanctions targeting the provision of insurance or reinsurance services relating to aviation and space goods or technology to a person connected with Russia or for use in Russia have also been implemented.

Possible introduction of strict liability for sanctions violations

In addition to the above measures, the UK authorities indicated that additional sanctions will be imposed in the coming days.  Most importantly, this may include a new strict liability standard for sanctions violations in the new Economic Crime (Transparency and Enforcement) Bill.  A strict liability standard would allow civil (i.e., non-criminal) monetary penalties to be imposed for even unintentional breach of UK sanctions, akin to the United States’ strict liability standard for most non-criminal sanctions breaches. 

Russian countermeasures target transactions in foreign currency; not full countersanctions

The Russian Federation has adopted countermeasures in response to the recent sanctions imposed on Russia.  The objectives of the measures appear to be to retain funds in Russia, restrict Russian residents (citizens and legal entities) from transacting in foreign currency and inhibit foreign investors from exiting their positions in Russia.

Three Presidential Decrees have been issued within the last ten days:

• Decree No. 79, adopted on February 28, 2022 (February 28 Decree): requires Russian residents to sell 80 percent of the foreign currency proceeds derived from foreign transactions or transactions with non-residents and credited to residents’ bank accounts within three days after receipt. Russian residents are also prohibited from (i) providing foreign currency to non-residents under loan agreements (which may only apply to new loans and new tranches according to the CBR guidance), or (ii) crediting foreign currency to their accounts outside of Russia and/or transferring funds without opening a bank account through any foreign electronic payment service providers. In addition, public joint stock companies are permitted to buy back shares issued by them provided certain conditions are met.
• Decree No. 81, adopted on March 2, 2022 (March 2 Decree): prohibits transactions listed in (i) and (ii) above and the following transactions between Russian residents and “foreign persons associated with foreign states which carry out hostile actions against Russia”: (i) the provision of loans or credit (in rubles) to such foreign persons, and (ii) transactions creating title to securities or real estate, without a government permit.
• Decree No. 95, adopted on March 5, 2022 (March 5 Decree): subject to comments by the CBR, which may be issued shortly, the March 5 Decree introduces a special procedure for the performance by all Russian residents of their obligations under facility agreements and financial instruments with entities incorporated or having their primary place of business or income in, or individuals who are citizens of, or persons controlled by, “Unfriendly States” (including Ukraine, the United States, the UK, the EU member states, and others) (the Affected Non-Residents). Russian residents may make debt repayments to Affected Non-Residents of over RUB 10m per month (or the equivalent amount in another currency) only if the Russian resident opens a special ruble-denominated account with a Russian bank, in Russia, in the name of the Affected Non-Resident lender to receive the payment in rubles, or applies to the Ministry of Finance or CBR for approval to discharge the obligations in another manner.  

These measures are likely to result in significant volumes of foreign capital being trapped in Russia.  Non-Russian companies looking to exit investments in Russia will face challenges in returning any funds realized back to their home jurisdictions.

In addition, Russia has implemented a new law that bans “fake news” about the Russian armed forces, punishable by up to 15 years imprisonment.  The new law applies to all individuals in Russia and includes all news and information distribution, including social media. 

Conclusion and recommendations

The coordination and severity of US, EU, and UK sanctions and export controls imposed on Russia in response to the escalating crisis in Ukraine continues to increase.  Further restrictions and measures are expected as the United States, EU, UK and other countries continue to clamp down on international dealings related to Russia.  This includes path-breaking measure like the UK’s revamped approach to sanctions and the EU and UK’s revised export controls regimes.

In response, Russia has imposed its own countermeasures, which will create challenges for companies whether they decide to continue or suspend Russia-related business.

Companies can take further steps to ensure compliance with these sanctions and export controls, including understanding transactions conducted within Russia and cross-border; taking stock of exports of goods, software, and technology; and planning for potential future escalation of sanctions.

We will continue to monitor the situation closely and provide further updates as it develops.

Visit our Russia sanctions hub for the latest insights and resources.