Category: z-Exclude

In previous posts, we outlined measures imposed by states in response to Russia’s recognition of Donetsk and Luhansk. Following Russia’s invasion of Ukraine on 24 February 2022, various states have enacted a new tranche of measures in response and announced further measures to be imposed over the coming days. We outline below the further actions taken by the US, EU, UK, Canada, and Australia since our last update. The most significant developments represent: The designation of VTB by the US…

Russia’s decision on 21 February 2022 to recognise the Donetsk and Luhansk regions of eastern Ukraine (the Covered Regions) as independent states, has prompted the US, UK, and, potentially, the EU to respond with the imposition of a first tranche of financial and trade sanctions. In this post, we consider the measures that have been imposed. US The US has imposed sanctions concerning the Covered Regions through an Executive Order issued on 21 February (the “EO”). The EO expands the…

The US, UK and EU have threatened to impose a range of measures to deter Russian activities in or against Ukraine. The scope and severity of such measures will likely give rise to serious compliance challenges for companies with Russian counterparties or who do business in Russia. In this post, we consider the types of measures which could be imposed by the US and their potential impact. Current Status of US Legislation The two houses of US Congress are nearing…

As part of its response to the current situation in Ukraine, the UK Government has recently enacted sanctions legislation which introduces additional grounds for designations of individuals and entities under the existing UK-Russia sanctions regime. However, no new designations have been made under these grounds. In this post, we consider the implications and potential impact of these changes. What Amendments Have Been Made? Prior to the recent amendments, the UK-Russia sanctions regime (contained in The Russia (Sanctions) (EU Exit) Regulations…

The Court of Justice of the European Union (the Court) has, for the first time, provided its interpretation of Article 5 of the EU Blocking Regulation, which prohibits EU persons from acting in compliance with certain sanctions imposed by the US on Iran and Cuba. In this update, we provide an overview of the Court’s decision and consider the implications of the issues addressed. Factual Background The Court addressed four interpretive questions regarding the EU Blocking Regulation[1] which were referred…

The UK has implemented new sanctions restricting entry into British ports and enabling the detention of certain Russian linked vessels. The Russia (Sanctions) (EU Exit) (Amendment) (No. 4) Regulations 2022, which amend the Russia (Sanctions) (EU Exit) Regulations 2019 (the Regulations) prevent certain vessels from entering British ports as well as authorising the Secretary of State for Transport to give directions to harbour authorities to restrict the movement of vessels (directing them to proceed to certain areas of a port or…

The US, EU, UK, Canada and Australia have continued to enact additional sanctions packages in response to Russia’s invasion of Ukraine. In this post, we outline some of the measures imposed since our last update. Our previous updates on sanctions imposed on Russia in relation to its activities in Ukraine can be found here, here, here, here and here. US On 25 February 2022, the US imposed sanctions on Russian President Vladimir Putin, Russian Foreign Minister Sergey Lavrov, Russian Minister of Defense Sergei Shoigu…

The world is seeing rapid changes to sanctions laws in response to Russia’s invasion of Ukraine. Australia is moving in lockstep with other countries imposing targeted financial sanctions and travel bans on Russian business and key individuals involved. This update summarises the Australian sanctions announced in response to the Russian invasion of Ukraine. It is critical that businesses in Australia who have exposure to Russian trade or investment ensure that their sanctions compliance framework is up to date and they…

The US and EU, and others, have indicated that they intend to “remove certain Russian banks from the SWIFT messaging system”. But what is SWIFT and how might the US and EU seek to flip the SWIFT switch, turning off Russian access to it? What is SWIFT? SWIFT (formerly the Society for Worldwide Interbank Financial Telecommunications) is not a clearing institution; it does not hold or transfer funds itself. Rather, it is the provider of the principle messaging systems used by…

On 10 March 2022, the UK Foreign Secretary, Liz Truss, announced sanctions against seven Russian Oligarchs, including Chelsea Football Club owner, Roman Abramovich. Under the terms of the sanctions, the oligarchs will have their assets in the UK frozen, be banned from travelling to the UK and no UK citizen or company may do business with them. Discussing the sanctions, Prime Minister, Boris Johnson, said: “There can be no safe havens for those who have supported Putin’s vicious assault on…