This month has seen – for the first time since February – no substantive changes to the US, UK and EU sanctions programs, including to measures related to Russia’s invasion of Ukraine. Nonetheless, there have been multiple high-profile designations, and two notable reports published on the effectiveness of sanctions on Russia:
- Two high-profile reports have been authored this month in the US and UK examining the effectiveness of western sanctions on Russia. The Yale Chief Executive Leadership Institute published a paper which argued that an exodus of over 1,000 global companies is having a severe effect on the Russian economy by exacerbating its “internal structural weaknesses”. In the UK, the Office for National Statistics published a report outlining import and export levels between the UK and Russia since the invasion, including an overall decrease of 96.6% in imports to the UK of goods from Russia compared to the twelve-month average prior to February 2022.
- OFAC imposed a number of new Russia-focused designations this month, listing oligarch Andrey Grigoryevich Guryev, a former head of PhosAgro, one of the world’s largest producers of phosphate-based fertilizers, as well as his son Andrey Andreevich Guryev. The US also imposed sanctions on a senior executive at steel producer MMK and two of its subsidiaries, as well as JSC Promising Industrial Infrastructure Technologies and its General Director. Four nationals were listed for having supported Russia’s “global malign influence operations and election interference activities”.
- On the enforcement side, a warrant has been issued by the US District Court for the Southern District of New York for the seizure of an Airbus A319 owned by Russian oligarch Andrei Skoch, said to be worth approximately US 90 million and located presently in Kazakhstan. Skoch is a member of Russia’s lower state legislature, the Duma, and a former business partner of Alisher Usmanov.
- Alongside OFAC’s new Russia designations, the US State Department imposed visa restrictions on 893 Russian officials, including members of the country’s upper legislature, the Federation Council, and members of its military, as well as 31 foreign government officials who have acted in support of Russia’s annexation of Crimea. Furthermore, on the anniversary of the 2020 Belarusian presidential election, the State Department announced the imposition of visa restrictions on 100 state officials and their affiliates in the country for their alleged role in undermining democratic institutions or impeding its transition to democracy.
- On 4th August the EU designated former President of Ukraine Viktor Yanukovych and his son Oleksandr Yanukovych pursuant to its Russia sanctions program for their alleged role in undermining or threatening the territorial integrity, sovereignty, and independence of Ukraine, separately accusing Oleksandr Yanukovych of conducting transactions with separatist groups in the Donbas.
- In non-Russia related news, OFAC designated the Solicitor General and Chief Prosecutor of Liberia, Sayma Syrenius Cephus, under its Global Magnitsky program for his alleged involvement in corruption. The designation followed a joint report authored by Omnia Strategy LLP and Alaco Ltd into allegations made by Cephus’s department against a leading political opponent, which the report demonstrated were without merit, leading to the dropping of all charges.
- Additionally, OFAC designated four entities said to be used by Iran’s Persian Gulf Petrochemical Industry Commercial Co to facilitate the sale of petroleum and petrochemical products from Iran to East Asia. OFAC also designated the virtual currency mixer Tornado Cash, which operates on the Ethereum Blockchain and is said to have been used to launder virtual currency worth $7 billion since its creation in 2019, pursuant to its Cyber program, and the Vice President of Paraguay for alleged involvement in significant corruption, under the Global Magnitsky program.
- OFSI added three entities to its Myanmar sanctions list in an effort to limit the country’s military’s access to arms and revenue.
