Key developments in Western sanctions programmes over the past month have involved harsher measures targeting the Russian economy in response to its invasion of Ukraine. These have included further trade embargoes against strategic sectors of the Russian economy, alongside the designations of a raft of additional oligarchs and political figures. Significant new measures have included:
- On 5th April the EU announced its fifth sanctions package in respect of Russia, comprising an import ban on coal, wood, cement, seafood and liquor, a full transaction ban on four key Russian banks, a ban on Russia-flagged vessels from accessing EU ports, and an export ban on sensitive technologies, including quantum computers. Russian companies are now also subject to a general EU ban on participation in public procurement in EU member states.
- The new measures were accompanied by the designation of 216 individuals, including oligarchs and family members of previously sanctioned individuals. Among these new designations were the adult daughters of Vladimir Putin, Maria Vorontsova and Ekaterina Tikhonova, the CEO of Sberbank Russia, German Gref and all 179 members of the breakaway governments and parliaments of Donetsk and Luhansk. On April 13th these new measures were adopted in full by SECO. EUROPOL has also launched an operation, code-named Oscar, to support investigations by Members States in freezing the assets of EU-sanctioned entities and individuals.
- On 14th April the UK expanded the terms of its sectoral Russian sanctions to encompass prohibitions against the export to Russia of luxury goods or the supply to the country of iron or steel products. The UK’s Russia related designations this month included three London law firms, Photon Pro LLP, Majory LLP and Djeco Group LP, for alleged involvement in a sanctions evasion network, as well as eight individuals and entities tied to Russia, including Boris Rotenberg and state-owned Sberbank.
- OFAC’s new Russia-related designations this month included state-owned diamond mining company Alrosa, Putin’s adult daughters, Russian Prime-Minister Mikhail Mishustin, as well as members of Foreign Minister Sergei Lavrov’s family, and an additional 16 members of Russia’s National Security Council. OFAC also targeted Russian darknet market, Hydra, and virtual currency exchange, Garantex, under its Cyber program.
- In non-Russia related updates, OFAC has designated seven individuals as part of its Balkans program, as well the the Kinahan Organized Crime Group in Ireland, along with seven of its key leadership figures, as part of its Transantional Criminal Organizations program. Five new entities were designated pursuant to OFAC’s non-proliferation sanctions regime for providing support to North’s Korea’s development of WMD and ballistic missile programs.
- There are also further indications that the UK is continuing to grow the resources it devotes to designing and implementing sanctions programmes. On 2nd April the UK House of Commons Treasury Committee published its report “Defeating Putin: the development, implementation and impact of economic sanctions on Russia” which contained recommended an increase in OFSI’s resources and an acceleration of UK’s transition to a secure energy supply. It also called for the government to maintain a “watchful eye” on how cryptocurrencies are used to evade sanctions.
