Update: New EU Sanctions Take Aim at Russia

February 24, 2022

In response to the conflict in Ukraine, on 23 February, the European Union introduced a sanctions package of five new regulations against Russia, including freezing assets and curbing trade with two non-government-controlled areas of Ukraine.

Council Regulation 2022/261: 336 members of the Russia State Duma (who voted in favour of the independence of the self-proclaimed Donetsk and Luhansk “republics”) have become designated persons, meaning asset freeze measures and an EU travel ban are imposed.

Council Regulation 2022/260: 22 individuals and 4 entities (VEB.RF, Bank Rossiya, Internet Research Agency, and Promsvyazbank) have also been designated.

Council Regulation 2022/259: There is an unwinding period until 24 August 2022, for the termination of operations, contracts, or other agreements, including correspondent banking relations, concluded with VEB.RF, Bank Rossiya, or Promsvyazbank before 23 February 2022.

Council Regulation 2022/262: A sectoral prohibition on purchasing, selling, providing investment services for or assistance in the issuance of, or otherwise dealing with transferable securities and money market instruments after 9 March 2022 by Russia, the Central Bank of Russia, or entities or bodies acting on behalf or at the direction of the Central Bank of Russia. However, there are limited exceptions to this prohibition.

Council Regulation 2022/263: Several prohibitions and restrictions in relation to the non-government-controlled areas of the Donetsk and Luhansk oblasts of Ukraine, including

  • a ban on imports into the European Union;
  • an export ban in relation to certain goods and technologies that could be used in the transport, telecommunications, energy, oil, gas, and minerals sectors;
  • prohibitions on technical assistance, brokering, construction, or engineering services relating to the infrastructure of the transport, telecommunications, energy, oil, gas, and minerals sectors;
  • prohibitions on supplying tourism services; and
  • prohibitions and restrictions on investments in certain sectors.

The European Union has stated that “it stands ready to swiftly adopt more wide-ranging political and economic sanctions in case of need.” There was a further meeting of the European Council on 24 February 2022, and it is expected that the European Union will introduce further sanctions in the near future, especially in light of reports of Russian operations in Ukraine.

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If you have any questions or would like more information on the issues discussed in this LawFlash, please contact any of the following Morgan Lewis lawyers:

Ukraine Task Force
Giovanna M. Cinelli
Joanna Christoforou
Bruce Johnston
Grigory Marinichev
Michael Masling
Kenneth J. Nunnenkamp
Georgia M. Quenby
Christina Renner
Melanie Ryan
Vasilisa Strizh
Carl A. Valenstein
Alexey Chertov
Jiazhen (Ivon) Guo
Katelyn M. Hilferty
Nicola Kelly
Christian Kozlowski
Daniel Lopez Rus
Charles C. Rush
Eli Rymland-Kelly