The EU has responded to the conflict in Ukraine with the following sanctions (listed by date, starting with the most recent):
March 15, 2022: The Council approved a fourth package of sanctions against Russia. The sanctions included a ban on transactions with certain state-owned companies and an expansion of the list of individuals associated with Russia’s defense and industrial base who are subject to stricter export restrictions on dual-use items and goods and technology used in the could contribute to Russia’s technological improvement of its defense and security sector.
In addition, restrictions on new investments in the entire Russian energy sector were imposed, as well as a comprehensive export restriction on equipment, technology and services for the energy industry in Russia, with the exception of the nuclear industry and the downstream sector of energy transport.
Also, sanctions (effective from April 15, 2022) were imposed on the rating of Russia and Russian companies by EU rating agencies and the provision of rating services to Russian clients, leading to a further loss of access to EU financial markets. The Council also introduced further trade restrictions in relation to iron and steel and luxury goods and introduced the ban on selling, supplying, transferring or exporting these goods, directly or indirectly.
The council also approved a new sanctions package that would list key oligarchs (including Roman Abramovich and German Khan) and prominent businesspeople in the iron and steel, energy, banking, media, military, and dual-use products and services sectors on the sanctions list Assets frozen and travel ban imposed. Sanctions are also imposed on lobbyists and propagandists, as well as on companies in the aviation, military/dual-use, shipbuilding and engineering sectors.
March 11, 2022: After a meeting in Versailles on March 10, European leaders announced that they reiterated their support for Ukraine and their willingness to impose further sanctions on Russia and Belarus. In addition, the statement called for funds to be made available “immediately” through the adoption of the Cohesion Action for Refugees in Europe (CARE) proposal and through ReactEU.
The statement also expressed support for Ukraine’s accession to the EU, noting that the Council has also called on the European Commission to deliver its opinions on the applications of the Republic of Moldova and Georgia.
Leaders of the Group of Seven (G7) issued a statement reaffirming their commitment to sanctions against Russia and affirming efforts to reduce energy dependency on Russia by means, “[i]n in addition to announced plans.” The statement also indicated that the G7 will go through their national procedures to deny Russia most-favoured-nation status for certain products. In addition, the statement cited efforts to block Russia from receiving funding from multilateral financial institutions, including the International Monetary Fund, the World Bank and the European Bank for Reconstruction and Development.
March 9, 2022: The Council approved the decision to ban three Belarusian banks from accessing SWIFT and prohibiting (i) transactions with the Central Bank of Belarus, (ii) listing of Belarusian state-owned companies on EU trading venues from April 12, 2022, (iii ) accepting deposits in excess of €100,000 from Belarusian nationals or residents; and (iv) supplying euro banknotes to Belarus.
In addition, the Council introduced additional restrictive measures in relation to exports of sea navigation goods and radio communication technology to Russia. As a result of this decision, it is prohibited to sell, supply, transfer or export goods and technology for maritime navigation, directly or indirectly, to any natural or legal person, entity or body in Russia for use in Russia or for placement on board a ship under Russian Flag.
The Council also expanded the list of legal persons, entities and bodies subject to the prohibitions relating to investment services, transferable securities, money market instruments and credit.
Finally, the Council clarified the term “transferable securities” to clearly include crypto assets, thus ensuring the proper implementation of the existing sectoral restrictions.
The Council approved a decision to place 14 oligarchs and businessmen and 146 members of the Council of the Russian Federation on the EU sanctions list.
March 2, 2022: The Council approved the decision to ban certain Russian banks from SWIFT, to ban them from participating in projects financed by the Russian Direct Investment Fund and to ban the sale, supply, transfer or export of euro banknotes to Russia.
In addition, the Council suspended the broadcasting of Sputnik and RT/Russia Today in the EU.
The Council also approved sanctions against 22 senior Belarusian military personnel (asset freeze and travel ban) and imposed export controls on dual-use goods and technology products, particularly those used for military and defense purposes.
February 28, 2022: The Council of the EU (Council) approved the decision to close EU airspace to all Russian-owned, registered or controlled aircraft. Transactions with the Russian central bank were prohibited.
In addition, the Council approved 26 more persons added and 1 more legal entity with asset freeze and travel ban within the EU sanctions package.
February 27, 2022: European Commission President Ursula von der Leyen announced the closure of EU airspace to all Russian-owned, registered or controlled aircraft. It was also decided to ban the state-run RT/Russia Today and Sputnik and their subsidiaries.
February 26, 2022: The European Commission, France, Germany, Italy, UK, Canada and the US have issued a joint announcement to impose further targeted sanctions on Russia, namely by removing Russian banks from the SWIFT banking system and imposing restrictive measures on the Russian Central Bank . Further coordination by a transatlantic task force was agreed.
February 25, 2022: EU foreign ministers approved sanctions targeting the financial, energy and transport sectors, dual-use goods, export controls and export financing, and visa policy. Export bans on oil refining technology, aircraft, spare parts and equipment to Russian airlines, as well as sensitive technology were included in the sanctions package. Russian President Putin and Foreign Minister Lavrov have also been the target of sanctions including an asset freeze and a travel ban to the EU.
February 24, 2022: The EU heads of government have agreed on a package of sanctions
February 23, 2022: Existing EU sanctions were extended to 351 members of the Russian Duma, 27 high-profile individuals and 52 organizations. The sanctions include asset freezes, restricted access to financial markets and export bans on a range of products, including aluminium.
Our related publications:
Additional US, UK and EU sanctions against Russia (March 2022)
The US, UK and EU are imposing a series of new targeted and territorial sanctions linked to Russia(February 2022)
Russia Sanctions Update: What Risk Management Steps Can Be Taken Now? (February 2022)
Transatlantic Trade | USA and Europe
© Copyright 2022 Squire Patton Boggs (US) LLPNational Law Review, Volume XII, Number 81
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