In light of the recent events in Ukraine, the European Union, United States of America, United Kingdom, Switzerland, Canada, Japan, and Australia have imposed a broad range of sanctions and export controls against Russia, and Russia, in its turn, imposed a number of retaliatory measures. These new sanctions are complex, multilateral and continue to be incrementally changing in real time in response to the developments on the ground in Ukraine.  We keep monitoring the situation closely and we will endeavor to with the most up-to-date information.

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Events

Sanctions overview

International Sanctions

  • EU SANCTIONS

    EU   
    Updated: October 10, 2022

    The Council of the European Union agreed on the 8th package of EU sanctions. The following measures are included:
    • the legal basis to put in place a price cap related to the maritime transport of Russian oil for third countries and further restrictions on the maritime transport of crude oil and petroleum products to third countries
    • the sanctioning of individuals and entities that have played a role in the organization of the “referenda”, representatives of the defense sector, as well as other well-known persons. The Council also decided to broaden the listing criteria on which specific designations can be based, in order to include the possibility to target those who facilitate the circumvention of EU sanctions
    • the extension of the list of restricted items that may contribute to Russia's military and technological enhancement or the development of its defense and security sector. The list will now include certain electronic components, additional chemicals, and goods that can be used for capital punishment, torture, or other cruel, inhuman, or degrading treatment
    • a prohibition to sell, supply, transfer, or export civilian firearms and their essential components and ammunition, military vehicles and equipment, paramilitary equipment, and spare parts
    • a ban on EU nationals to hold any posts on the governing bodies of certain Russian state-owned or controlled legal persons, entities, or bodies
    • the insertion in the list of state-owned entities that are subject to the transaction ban of the Russian Maritime Shipping Register, a 100% State-owned entity that performs activities related to the classification and inspection, including in the field of security, of Russian and non-Russian ships and crafts 
    • a full ban on the provision of crypto-asset wallet, account, or custody services to Russian persons and residents, regardless of the total value of those crypto-assets
    • the prohibition to provide architectural and engineering services as well as IT consultancy services and legal advisory services to Russia
    • the extension of the geographical scope of the restrictions, including notably the import ban on goods from the Russian-controlled areas of the Donetsk and Luhansk oblasts, to cover also the Russian-controlled areas of the oblasts of Zaporizhzhia and Kherson



    The Council of the European Union decided on September 14, 2022, to prolong the duration of the restrictive measures “targeting those responsible for undermining or threatening the territorial integrity, sovereignty and independence of Ukraine” for a further six months, until 15 March 2023. The existing restrictive measures provide for travel restrictions for natural persons, the freezing of assets, and a ban on making funds or other economic resources available to the listed individuals and entities. Sanctions will continue to apply to 1206 individuals and 108 entities.

    On September 9, 2022, the European Commission published guidelines to handle short-stay visa applications submitted by Russian citizens. According to the Commission’s communication, it is recommended, inter alia, that “consulates should conduct a strict assessment of security risks.” The European Commission recommended to extend the period for deciding on visa applications up to 45 days and minimize the issuance of multiple-entry visas. It also recommended to EU countries to simplify the visa issuance process for Russian civil society representatives and ‘dissidents’.

    On September 6, 2022, the European Commission proposed to fully suspend the EU's Visa Facilitation Agreement with Russia. This means that Russian citizens will no longer enjoy privileged access to the EU and face a lengthier, more expensive and more difficult visa application process. The proposal was further detailed during the press conference by Ylva Johansson, the European Commissioner for Home Affairs. In practice, it will lead to the following:
    • The visa fee will increase from €35 to €80 for all Russian applicants.
    • The standard deadline for consulates to take a decision on visa applications will increase from 10 to 15 days (with the maximum of 45 days in individual cases).
    • Applicants will no longer have easy access to visas valid for multiple entries to the Schengen area.
    • Applicants will have to submit the full list of documentary evidence when applying for a visa.
    The EU will remain open to certain categories of Russian visa applicants travelling for essential purposes, including notably family members of EU citizens, journalists, dissidents and civil society representatives.


    The European Union has expanded the personal sanctions list to include State Duma deputies Alla Polyakova and Anton Tkachev, as well as a member of the Federation Council Valery Ponomarev. Information about this appeared in the official journal of the European Union. It is noted that the decision comes into force from the moment of publication of the document.

    Previous EU sanctions

  • US SANCTIONS

    USA   
    Updated October 11, 2022

    | On September 15, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated 22 individuals and 2 entities, including multiple individuals who have supposedly “furthered the Government of the Russian Federation’s (GoR) objectives in Ukraine, in 2022”. Also included among those being designated is Task Force Rusich, a paramilitary group that has participated in combat alongside Russia’s military in Ukraine, as well as two of its senior leaders. In addition, the U.S. Department of Commerce is imposing additional export control measures to further align with partners and allies and the U.S. Department of State is targeting Russia’s defense and high-technology industries, as well as proxy authorities. OFAC is also issuing Russia-related General License 51 "Authorizing the Wind Down of Transactions Involving Limited Liability Company Group of Companies Akvarius", and publishing three Russia-related Frequently Asked Questions (1080 - 1082).

    The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) published preliminary guidance on the implementation of a maritime services policy and related price exception for seaborne Russian oil. As part of a coalition of countries including the G7 and the EU, the United States will implement a policy with regards to a broad range of services related to the maritime transportation (the “maritime services policy”) of Russian Federation origin crude oil and petroleum products (“seaborne Russian oil”). This ban will take effect on December 5, 2022 with respect to maritime transportation of crude oil and on February 5, 2023 with respect to maritime transportation of petroleum products. This policy, constructed as a ban on services, will have an important exception: jurisdictions or actors that purchase seaborne Russian oil at or below a price cap to be established by the coalition (the “price exception”) will expressly be able to receive such services. This policy is intended to expressly establish a framework for Russian oil to be exported by sea under a capped price and achieve three objectives:
    • maintain a reliable supply of seaborne Russian oil to the global market
    • reduce upward pressure on energy prices
    • reduce the revenues the Russian Federation earns from oil after the conflict in Ukraine has inflated global energy prices.

    The Department of the Treasury's Office of Foreign Assets Control (OFAC) is issuing Russia-related General License 13B. Consistent with GL 13A, GL 13B continues to authorize, subject to certain conditions, US Persons to pay taxes, fees, or import duties and to purchase or receive permits, licenses, registrations, or certifications, to the extent such transactions would otherwise be prohibited on the basis that they involve the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of Russia, and provided such transactions are ordinarily incident and necessary to such persons’ day-to-day operations in Russia until December 7, 2022.

    On September 2, Secretary of the Treasury Janet L. Yellen issued a separate statement on the price cap policy. In addition, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) anticipates publishing preliminary guidance on the implementation of the price cap in September. The preliminary guidance will provide a high-level overview of this mechanism, including how U.S. persons can comply, in advance of formal guidance and legal implementation to be issued at a later date.

    Previous US sancions

  • UK SANCTIONS

    ASSET FREEZE ON INDIVIDUALS  

    Imposed by the HM Treasury’s Office of Financial Sanctions Implementation on February 24
    • Gennadiy Nikolayevich TIMCHENKO
    • Boris Romanovich ROTENBERG
    • Igor Arkadyevich ROTENBERG

    Russian President and Foreign Minister were added to the sanctions list on February 25, 2022
    • Vladimir Vladimirovich PUTIN 
    • Sergei Viktorovich LAVROV 

    On March 1 the following individuals were added to the list:
    • Andrei Burdyko  
    • Victor Vladimirovich Gulevich  
    • Sergei Simonenko  
    • Andrey Zhuk  
    • Kirill Alexandrovich DMITRIEV

    On March 10 the UK included in its consolidated lists of sanctions a number of individuals who are subject to an asset freeze. The list includes oligarchs who are close to the Russian regime, namely:
    • Roman Abramovich
    • Igor Sechin
    • Oleg Deripaska
    • Dmitry Lebedev
    • Alexey Miller
    • Andrey Kostin
    • Nikolay Tokarev

    On March 11 the UK included in its consolidated lists of sanctions 386 members of the State Duma - politicians who voted to recognise independence of territories in Ukraine. The new sanctions will ban those listed from travelling to the UK, accessing assets held within the UK and doing business here.

    On March 15 the UK has expanded sanctions against the Russian Federation, introducing new restrictions against more than 345 Russian individuals. Among others: Dmitry Medvedev, Mikhail Mishustin, Sergei Ivanov, Maria Zakharova, Sergei Solovyov, Olga Skabeeva, Tigran Keosayan, Roman Babayan, Zakhar Prilepin, Anton Krasovsky, Arkady Mamontov, Sergei Sobyanin, Konstantin Ernst.

    On March 24 The British government has added 33 individuals and 26 entities to the sanctions list. The expanded list includes the head of Sberbank German Gref, as well as the former deputy chairman of the organization Lev Khasis, Russian businessmen Oleg Tinkov and Yevgeny Shvidler, Deputy Defense Minister Dmitry Bulgakov and head of the Federal Service for Military-Technical Cooperation Dmitry Shugaev. Companies now on the list include Gazprombank, Alfa Bank, Rosselkhozbank, Sovcomflot, Russian Railways, RusHydro.

    On April 13, the UK government has expanded the list of sanctions against Russian citizens, imposing restrictions on more than 200 individuals and organizations, follows from a statement on the website of the British government. Were added among others:

    • the head and co-owner of Lukoil Vagit Alekperov,
    • the general director and co-owner of Surgutneftegaz Vladimir Bogdanov,
    • vice-president of Gazprombank Sergey Fursenko,
    • chairman of the board of directors of AFK Sistema Vladimir Yevtushenkov,
    • ex-president Russian Railways Vladimir Yakunin, 
    • owner of Transmashholding JSC Andrey Bokarev.
    • the head of the political council of the Ukrainian party "Opposition Platform - For Life" Viktor Medvedchuk,  
    • the wife of Russian Foreign Minister Sergei Lavrov

    On April 21 the UK Foreign Secretary has announced a new wave of 26 designations – targeting defence actors, more particularly Generals as well as individuals and businesses supporting President Putin’s military.


    FINANCE  

    Asset freeze on financial institutions:
    Imposed by the HM Treasury’s Office of Financial Sanctions Implementation on February 24
    • BANK ROSSIYA
    • BLACK SEA BANK FOR DEVELOPMENT AND RECONSTRUCTION
    • JOINT-STOCK COMPANY GENBANK
    • IS BANK PUBLIC JOINT STOCK COMPANY PROMSVYAZBANK

    On February 28 and March 1, the following banks were added to the list:
    • VEB.RF 
    • BANK OTKRITIE FINANCIAL CORPORATION PJSC 
    • PJSC SOVCOMBANK
    • PJSC SBERBANK (PUBLIC JOINT-STOCK COMPANY SBERBANK) 
    • RUSSIAN DIRECT INVESTMENT FUND 
    Asset freeze on entities:
    • UNITED AIRCRAFT CORPORATION  
    • URALVAGONZAVOD  
    • VTB BANK 

    Implemented on  February 24
    • JSC 558 Aircraft Repair Plant  
    • JSC Integral  

    Together with the new sanctions regulations, the Office of Financial Sanctions Implementation ("OFSI") issued three new general licences allowing a close of certain activities.

    On March 15, the UK added 5 legal entities to the sanctions list:
    • Gas industry insurance company SOGAZ
    • Geopolitica
    • Internet research agency
    • New Eastern Outlook
    • Oriental Review

    On April 1 the UK authorities have frozen the assets of three Russian companies, that are registered in the UK and dealing with electronic systems, telecommunications, mobile networks and film production:

    • Photon Pro LLP (Group ID: 15065)
    • Majory LLP (Group ID: 15066)
    • Djeco Group LP (Group ID: 15067)



    On April 6 the Foreign Secretary announced the following sanctions:

    • asset freezes against Sberbank and Credit Bank of Moscow. Sberbank is Russia’s largest bank and this freeze is being taken in co-ordination with the US.
    • an outright ban on all new outward investment to Russia. In 2020 UK investment in Russia was worth over £11 billion. This will be another major hit to the Russian economy and further limit their future capabilities.


    EXPORT BAN  

    On April 6 the Foreign Secretary announced the following sanctions:

    • by the end of 2022, the UK will end all dependency on Russian coal and oil, and end imports of gas as soon as possible thereafter. From next week, the export of key oil refining equipment and catalysts will also be banned, degrading Russia’s ability to produce and export oil – targeting not only the industry’s finances but its capabilities as a whole.
    • action against key Russian strategic industries and state owned enterprises. This includes a ban on imports of iron and steel products, a key source of revenue. 

    On April 21, the UK Government has announced further trade sanctions against Russia – expanding the list of products facing import bans and increasing tariffs. The UK will now be imposing import tariffs and bans on over £1bn of Russian goods. The new sanctions include import bans on silver, wood products and high-end products from Russia including caviar. UK will also increase tariffs by 35 percentage points on around £130m worth of products from Russia and Belarus, including diamonds and rubber. 


    AIR   

    On 25 February 2022, the Air Navigation (Restriction of Flying) (Russian Aircraft) Regulations 2022 were enacted and provide that no aircraft on a scheduled service which is owned, chartered or operated by a person connected with Russia, or which is registered in Russia shall fly in United Kingdom airspace, including in the airspace above the United Kingdom’s territorial sea, without a licence.

    On March 9, the UK Government announced a new suite of aviation sanctions:
    1. New powers to detain Russian aircraft and remove aircraft belonging to designated individuals and entities from the UK register
    2. Ban on the export of aviation and space-related goods and technology, including technical assistance
    3. Further ban on UK companies providing insurance and re-insurance services in relation to these goods and technology

  • SWITZERLAND SANCTIONS

    On February 28 the Federal Council took the decision to adopt the packages of sanctions imposed by the EU on 23 and 25 February. The assets of the individuals and companies listed are frozen with immediate effect; the financial sanctions against Russian President Vladimir Putin, Prime Minister Mikhail Mishustin and Foreign Minister Sergey Lavrov are also to be implemented with immediate effect.
    Related document:

    On March 4 Switzerland extended its sanctions against Russia, adopting a ban on many industrial exports and wide-ranging restrictions on financial activities, which includes cutting Russian banks from the SWIFT financial messaging system. The Swiss government also confirmed it is freezing the assets of oligarchs. Exports of material that could boost Russia’s military or technological capabilities are being particularly targeted in the sanctions. This includes technical assistance and financing of such exports. Banks and other financial companies will face restrictions in the trading of securities, issuing loans or accepting deposits. This includes transactions with the Russian central bank. Switzerland will also actively support EU measures to cut Russia off from the SWIFT financial messaging system that facilitates financial transactions. 

    On March 16 the Swiss authorities have announced the inclusion of further 197 individuals and 9 additional entities in the sanctions lists. Switzerland’s sanctions list now fully mirrors that of the EU. The individuals sanctioned include businessmen Roman Abramovich, Andrei Melnichenko, Alexander Vinokurov, Vadim Moshkovich, Dmitry Pumpyansk, Dmitry Mazepin, Rostelecom president Mikhail Oseyevsky, entrepreneurs and top managers Andrei Guryev, Dmitry Konov and Mikhail Poluboyarinov, and Channel One General Director Konstantin Ernst. The Russian companies sanctioned by Switzerland are Rosneft Aero, Rosoboronexport, JSC NPO High-Precision Systems, Kurganmashzavod, JSC Russian Helicopters, the United Aircraft Corporation, the United Shipbuilding Corporation, Uralvagonzavod, and JSC Zelenodolsk Plant named after A.M. Gorky.

    On 13 April, the Federal Council of Switzerland took the decision to adopt the 5th package of EU sanctions against Russia and Belarus. Furthermore, the Federal Department of Economic Affairs, Education and Research (EAER) has imposed financial sanctions and travel restrictions on a further 200 individuals. 

  • JAPAN SANCTIONS

    FINANCE  

    On February 23 Japanese government has decided to take the following economic sanctions measures: 
    • Suspend issuing visas for officials from the two regions, the DPR and the LPR, and also freeze their assets;
    • Ban exports to and imports from the same regions; 
    • Ban the issuance and trading of new Russian sovereign bonds in Japan.

    Since May 12, Tokyo has frozen the assets of Sberbank and Alfa Bank and imposed restrictions on 398 individuals and 28 legal entities. 
    The sanctions were imposed on: 
    • Duma deputies and military personnel, including Navy Commander Nikolai Yevmenov and Army Commander Oleg Salyukov. 
    • Maria Vorontsova and Ekaterina Tikhonova, who are named as the daughters of President Vladimir Putin, as well as to Maria Lavrov and Ekaterina Vinokurova, the wife and daughter of Russian Foreign Minister Sergey Lavrov. 
    Japan also banned new investments in Russia and imposed an embargo on timber from Russia starting April 19, 2022.
     


    SANCTIONS AGAINST INDIVIDUALS AND ENTITIES  

    On February 28 the Japanese Foreign Ministry announces sanctions on Russian leaders, including President Vladimir Putin, over the Ukraine situation. The sanction list also features Russian Foreign Minister Sergei Lavrov, Russian Defense Minister Sergei Shoigu, Chief of the Russian Armed Forces General Staff Valery Gerasimov, Russian Security Council Secretary Nikolai Patrushev and Russian Security Council Deputy Chairman Dmitry Medvedev.  These sanctions also apply to 49 Russian agencies, financial institutions and companies, including, among others, the Federal Security Service of the Russian Federation (FSB), the Main Intelligence Department, JSC Company Sukhoi and JSC Russian Aircraft Corporation MiG, the Rostec state corporation, the Central Bank of Russia, VEB, and Promsvyazbank. 

    On March 8 Japan has published a new package of sanctions against Russia and Belarus. The export of oil refining equipment to Russia and products for the Ministry of Defense of Belarus is prohibited. 12 organizations came under sanctions, including PMC Wagner, Synesis and Beltechexport. The list also includes 20 Russians and 12 Belarusians. Among them are the press secretaries of the presidents of Russia and Belarus Dmitry Peskov and Natalya Eismont, the first deputy head of the presidential administration of the Russian Federation Sergey Kiriyenko, the deputy head of the administration Dmitry Kozak, the head of Chechnya Ramzan Kadyrov, the entrepreneurs Rotenberg brothers, Gennady Timchenko, the sons of the President of Belarus Viktor and Dmitry Lukashenko.

    On March 15 the Japanese Foreign Ministry has imposed sanctions against 17 Russian citizens, according to the ministry's website. The measures include freezing of assets on the territory of the country and prohibition of financial transactions with them.
    The restrictions affected the founder of Renova Group, Viktor Vekselberg, and five relatives of businessman Yuri Kovalchuk. The sanctions list also included 11 State Duma deputies:
    • Сommunist party leader Gennady Zyuganov
    • First Deputy Chairman of the State Duma Ivan Melnikov
    • First Deputy Head of the KPRF faction Nikolai Kolomeitsev
    • Yuri Afonin
    • Evgeny Bessonov
    • Leonid Kalashnikov
    • Vladimir Kashin
    • Aleksey Kurinniy
    • Dmitry Novikov
    • Nikolai Osadchii
    • Kazbek Taisaev

    On March 25 Japan's Foreign Ministry announced new sanctions against Russia. Restrictions were imposed against 25 Russians and 81 organizations. Tokyo has banned the export of luxury goods.
    Under the personal sanctions are Igor Shuvalov, chairman of VEB.Russia, Alexei Mordashov, general director of Severstal, Nikolai Shamalov, shareholder of Rossiya Bank, and members of their families. Also on the list were relatives of other Russians, including presidential press secretary Dmitry Peskov, First Deputy Head of the Presidential Administration Sergei Kirienko, Security Council Secretary Nikolai Patrushev, and businessmen Arkady and Boris Rotenberg. 

    On April 1 Japan imposed sanctions against three individuals and four legal entities from Russia for violating the sanctions regime against the DPRK, according to the website of the Japanese Foreign Ministry. 
    The list includes Russians Alexander Gaevoy and Alexander Chasovnikov, as well as the companies Apollon, RK Breeze, Zil-M and Parsek. They are accused of involvement in North Korea's nuclear and ballistic projects. Now all their assets in Japan will be frozen, the ministry said. In addition to the Russians and Russian companies, Japan also imposed sanctions on six North Korean citizens.


    EXPORT BAN  

    On March 16 the Ministry of Economy, Trade and Industry of Japan designated nearly 300 items and technologies as subject to an export ban on Russia and Belarus. The embargo on exports of 266 products, such as semiconductors, communication equipment and cutting-edge materials, and 26 technologies, including design programs for chip-making machines, takes effect on March 18. In addition, exports of oil-refining equipment and related technologies to Russia will be prohibited.

    The Japanese Government is banning the export of luxury goods to Russia from April 5. The restrictions apply to premium cars and gemstones, said Japanese Minister of Economy, Trade and Industry Koichi Hagiuda.

  • CANADA SANCTIONS

    On February 24, 2022, Canada further amended the Special Economic Measures (Russia) Regulations twice. 


    INDIVIDUALS   

    Entities are subject to a broad dealings ban:
    • VEB
    • Promsvyazbank PJSC
    • Central Bank of the Russian Federation
    • National Wealth Fund of the Russian Federation
    • Ministry of Finance of the Russian Federation
    • Sberbank
    • VTB
    • Russian Direct Investment Fund
    • Eximbank of Russia
    • Bank Otkritie Financial Corporation PJSC
    • Novikombank JSCB
    • Cetelem Bank
    • Alfa-Bank
    • Transkapitalbank PJSC
    • Ural Bank for Reconstruction and Development
    • Genbank
    • Black Sea Bank for Development and Reconstruction
    • Rostec
    • Sovcombank
    • Wagner
    • Rostelecom
    • RusHydro
    • Alrosa
    • Sovcomflot
    • Russian Railways
    • Gazprombank
    • Gazprom
    • Gazpromneft
    • Transneft
    • Russian Agricultural Bank
    • Tactical Missiles Corporation
    • United Aircraft Corporation

    It is prohibited for any person in Canada and any Canadian outside Canada to transact in, provide financing for or otherwise deal in new debt, directly or indirectly, including bonds, loans, debentures, extensions of credit, loan guarantees, letters of credit, bank drafts, bankers’ acceptances, discount notes, treasury bills, commercial paper and other similar instruments, issued by a designated person listed in sanctions list (Schedule 3.1) or in relation to: a designated person listed; the property of a designated person listed; or the interests or rights in property of a designated person listed 

    On March 11 Canada imposed new sanctions under the Special Economic Measures (Russia) Regulations. These new measures will impose restrictions on 32 entities working in Russia’s defence sector and on five current and former Russian senior officials.
    Individuals: Roman Abramovich, Ella Pamfilova, Alisher Usmanov, Elena Morozova, Igor Yanchuk

    Among entities, that fell under restrictions, there are Ministry of Defence of the Russian Federation, Irkut Corporation, Russian Helicopters JSC, Sukhoi Civil Aircraft.


    SANCTION AGAINST RUSSIAN AUTHORITIE   

    On February 28, 2022, Canada further amended the Special Economic Measures (Russia) Regulations to add eighteen members of the Security Council of the Russian Federation responsible for these actions, including President Vladimir Putin, Foreign Minister Sergei Lavrov, Minister of Defence Sergei Shoigu, Minister of Justice Konstantin Chuychenko, and Finance Minister Anton Siluanov. 

    On March 15 Canadian authorities imposed sanctions on 15 Russian officials, including Deputy Prime Minister Dmitry Grigorenko, Economic Development Minister Maxim Reshetnikov, and Defense Ministry spokesman Igor Konashenkov. The head of the National Center for Defense Control of the Russian Federation, the commander-in-chief of the Russian Navy, the commander of the Black Sea, the commander-in-chief of the Russian Aerospace Forces are also among those who fell under sanctions. 


    AIR  

    On February 27 government of Canada prohibited Russian aircraft to enter Canadian airspace. The Government of Canada is prohibiting the operation of Russian-owned, chartered or operated aircraft in Canadian airspace, including in the airspace above Canada’s territorial waters. 

  • AUSTRALIA SANCTIONS

    FINANCE  

    On February 28 the Australian Government supported restrictive economic measures against key Russian banks, institutions and individuals:
    • removal of selected Russian banks from the SWIFT global payments messaging system
    • restrictive measures to prevent the Russian Central Bank from using its international reserves in a way that undermines sanctions
    • limiting so-called golden passports for wealthy Russians connected to the Russian government
    • a trans-Atlantic task force to identify and freeze the assets of sanctioned individuals and companies that exist within their jurisdictions
    • restrictions on the export or supply, import, purchase or transport of certain goods
    • it is prohibited to deal with financial instruments issued by, or providing loans or credit to specified publicly‐owned or controlled Russian banks, specified Russian companies predominantly engaged in activities relating to military equipment or services, specified publicly‐owned or controlled Russian companies involved in the sale or transport of crude oil or petroleum products, majority owned subsidiaries or entities acting as agents for any of the above.
    • requirement to freeze assets of entities and individuals from the consolidated list (Consolidated List | Australian Government Department of Foreign Affairs and Trade (dfat.gov.au)


    INDIVIDUALS  

    On March 14 the Australian Government announced sanctions on 33 Russian oligarchs, prominent businesspeople and their immediate family members.

    On March 29, sanctions have been imposed on 14 Russians "responsible for serious corruption" and 25 other Russian citizens who, according to Canberra, were involved in the death of Sergei Magnitsky.

    On April 14, the Australian authorities have put 13 Russian legal entities on the sanctions list. In particular, the sanctions include:
    • KamAZ
    • Novorossiysk Commercial Sea Port
    • Roselectronics
    • United Shipbuilding Corporation
    • Sevmash
    • ALROSA
    • Sovcomflot
    • RUSSIAN RAILWAYS
    • Gazprom
    • Gazprom Neft
    • Transneft
    • Rostelecom
    • RusHydro
    • Sogaz

    On April 19, New Zealand has emposed sanctions on eighteen financial entities, including Russia’s central bank, sovereign wealth fund and the largest financial institutions in the country. These major institutions make up approximately 80% of Russia’s total banking assets. 
    This round of sanctions targets:
    • Three core government financial institutions, including banks and a key investment fund
    • Eight of the largest banks
    • Seven other banks of significance because of links to oligarchs, Russia’s defence sector and annexation of Crimea


    EXPORT BAN  

    On March 20 Australia banned exports of alumina and aluminum ores to Russia. Australian Foreign Minister Maris Paine announced new sanctions against Russia. Australian companies are banned from supplying alumina, aluminum ore, and bauxite to Russia. The Minisiter notes that the new sanctions will limit Russia's ability to produce aluminum, a "critical export" for the country. It is claimed that 20% of Russia's alumina needs are met by supplies from Australia.

    On March 31 Australia announced the cancel of the most-favored-nation treatment in trade for Russia and Belorussia and apply an additional duty of 35% to imports from these two countries. The decision was made by Australian Prime Minister Scott Morrison, according to the government's website.

    On April 6 the New Zealand authorities imposed a 35% tariff on all imports from Russia and also expanded existing restrictions on exports.

    Since April 7 Australia has prohibited the supply, sale or transfer of certain luxury goods directly or indirectly to, for use in, or for the benefit of Russia. The Autonomous Sanctions (Export Sanctioned Goods—Russia) Amendment (No.1) Designation 2022 (the Designation) designates certain luxury goods as ‘export sanctioned goods’ for Russia. 


    • Russian Countermeasures

  • FINANCE  
    Loan agreements
    From March 1, there is a ban only on the provision of funds to non-residents (including foreign companies and individuals) in foreign currency under the newly concluded loan agreements, as well as under the existing ones.
    Transfer of funds in foreign currency to non-residents under the existing loan agreements, concluded before March 1, should be immediately stopped.
    Currency operations on the receipt by non-residents of foreign currency in fulfillment of their obligations under the loan agreements previously issued by residents to non-residents are not limited (including operations on repayment by non-residents of the loan, payment by non-residents of amounts of interest and (or) penalties under the loan).
    Residents are not restricted in fulfillment of obligations to non-residents under loan agreements providing for extension of a loan by a non-resident to a resident.

    Residents are not prohibited from making payments in favor of non-residents both in Russian currency and in foreign currency for the purchase of goods by residents abroad, payment for services, including those related to utility payments for real estate located abroad, payment for education, medical services.
    Temporary procedure for paying debts by regions of Russia, municipalities and residents who have obligations to foreign creditors who are residents of those countries that have imposed sanctions against Russia.

    Permissions for specific operations
    Legal entities of the Russian Federation, citizens and other residents need to obtain permission  from the Governmental Commission for Control of Foreign Investment in the Russian Federation to carry out:
    - transactions for granting loans and credits (in rubles) to persons from "unfriendly" countries
    - any purchases of real estate or securities from counterparties of "unfriendly" countries
    The transactions entailing securities ownership rights, except for transactions of the Bank of Russia and state bodies, can be executed at the organized stock markets on the basis of the permission, issued by the Bank of Russia upon agreement with the Ministry of Finance of Russia.

    A permit may also be required for purchases from a counterparty from a country that is not considered "unfriendly" if the transaction is made by such counterparty with a person from "unfriendly" country after February 22, 2022.
    Banks may only transfer foreign currency to non-resident banks subject to these restrictions.
    More information available on  https://minfin.gov.ru/ru/permission/       

    Mandatory sale by exporters of 80% of foreign currency earnings

    Compulsory self-sale by residents of 80% of currency proceeds received under foreign trade contracts with non-residents. The requirement applies to any contracts, regardless of foreign trade registration.

    In particular, the calculation of 80% of the amount of foreign currency available in the resident's accounts as of February 28, 2022 and received from export activities during the period from January 1, 2022 to February 28, 2022.

    Compulsory sale of foreign currency proceeds is possible in parts, provided that all 80% of the amount of foreign currency subject to compulsory sale shall be sold within 3 business days from the date of receipt.

    This requirement applies to foreign currency received from non-residents in any foreign currency.

    Currency
    Legal entities, citizens and other residents are prohibited to transfer foreign currency to their accounts (deposits) abroad.

    It is prohibited for residents to make money transfers without opening a bank account using electronic means of payment provided by foreign payment services.

    From March 2, it is forbidden to take out of Russia cash foreign currency in excess of $10 thousand at the rate of the Central Bank on the date of export.
     
    There is a ban on withdrawal of over $10 thousand from citizens foreign currency deposits. It will be possible to withdraw more money, but the rest of the money will be available in rubles at the rate on the day of issue. The restrictions will be valid from March 9 to September 9, 2022. 

    Transfers from accounts of legal entities and individuals, non-residents (residents of "unfriendly" countries), opened in Russia, to accounts opened abroad, as well as transfers without opening bank accounts, including electronic money abroad, are suspended until March 31.

    Until March 31, restrictions are in effect on transfers by non-resident individuals (residents of foreign countries) without opening an account abroad in the amount of $5,000 per month.
    Related documents:
    AIRSPACE   

    There is a restriction on flights of air carriers from 36 countries.
    Flights of carriers from these countries can now be operated only after obtaining special permission from Rosaviatsiya or the Ministry of Foreign Affairs of Russia.
    Related documents:


    EXPORT    

    The Government has determined the list of goods and equipment temporarily banned for export from Russia. The decision will be valid until the end of 2022.
    The list includes technological, telecommunication, medical equipment, vehicles, agricultural equipment, electrical equipment - more than 200 items in total, including railway cars and locomotives, containers, turbines, metal and stone processing machines, monitors, projectors, consoles and panels.
    Export of these goods is temporarily restricted to all foreign countries, with the exception of EAEU member states, Abkhazia and South Ossetia. With regard to these countries there will be a licensing procedure for exports approved by a separate government decree. 




    • Practical information and FAQ

    Transportation and mobility

    Information on the routes to travel from Russia and back*. 
    Updated 14.07.2023


    By plane:
    - Algeria | Algeria
    - Belarus | Minsk 
    - Afghanistan | Kabul 
    - Armenia | Yerevan 
    - Azerbaijan | Baku 
    - Bahrain | Manama
    - China | Beijing
    - Cuba | Varadero
    - Egypt | Cairo, Hurghada, Sharm El Sheikh
    - Ethiopia | Addis Ababa
    - Georgia | Tbilisi, Batumi, Kutaisi
    - India | Delhi
    - Iran | Tehran
    - Iraq | Baghdad
    - Israel | Tel Aviv
    - Kazakhstan | Almaty, Aktobe, Nur-Sultan, Kostanay, Shymkent, Taldykorgan, Ust'-Kamenogorsk, Zhezkazgan
    - Kuwait | Kuwait
    - Kyrgyzstan | Bishkek
    - Mongolia | Ulan-Bator
    - Oman | Muscat
    - Qatar | Doha
    - Serbia | Belgrad
    - Tajikistan | Dushanbe
    - Turkey | Istanbul or Antalya
    - Turkmenistan | Ashgabat
    - UAE | Abu Dhabi, Dubai or Sharjah 
    - Uzbekistan | Tashkent 
    - Maldives
    - Seychelles
    - Thailand
    Carrier: https://www.aeroflot.ru (from October 30, 2022),  www.s7.ru (from November 2, 2022)

    By bus or private car:

    - Uzbekistan - Russia

    By train:

    - Kazakhstan - Russia 
    - Kyrgyzstan - Russia 


    *Please note that all the following flights are listed on carriers’ website, but we advise you to check the actual information directly with the respective airline. In addition, please check the vaccination or PCR test requirements for the selected route.
    ** From September 30, 10 categories are allowed to enter Finland: family members of Finnish citizens and family members of third-country nationals permanently residing in Finland; family members of citizens of an EU member state, a member of the European Economic Area or the Swiss Confederation; working in Finland; personnel in the field of transport and logistics in the performance of work duties; business travel; students; persons entering Finland for medical treatment; owners of apartments or real estate; staff of diplomatic and consular missions; other special justified reasons.

    Finance and payments

    Russian President Vladimir Putin signed a document according to which transactions of non-residents from unfriendly countries with more than 1% of stocks of Russian financial organizations must be approved by a government commission.
    Updated October 15, 2022


    Russian President Vladimir Putin granted the Central Bank of the Russian Federation the authority to issue permits for the export of foreign currency from the Russian Federation in the amount of more than $10,000, follows from a decree signed by the head of state on October 15.
    Updated October 15, 2022


    The Bank of Russia has developed additional procedures for setting official rates of foreign currencies in relation to the ruble, in order to more accurately reflect the situation on the markets. Additional alternative data sources - bank reports and digital OTC trading platforms - are provided for this purpose.
    Updated October 13, 2022


    A bill proposing to increase the number of banks and brokers entitled to participate in foreign exchange trading on the Moscow Exchange has been submitted to the State Duma. The project proposes to allow the Russian government to approve the list of countries which banks and brokers can participate in foreign currency trading on Moscow Exchange. The Bank of Russia will be able to establish requirements for foreign banks and foreign brokers to participate in trading and to limit the transactions carried out by them.
    Updated October 11, 2022


    The Federation Council approved the law on the granting of credit vacations to the mobilized.
    Updated October 4, 2022


    The Central Bank has developed additional procedures for establishing exchange rates of foreign currencies.
    Updated October 3, 2022


    The Bank of Russia extended for six months restrictions on transfers abroad of funds of non-residents from unfriendly countries from the accounts of brokers and trustees. The restrictions were introduced on April 1, 2022.
    Updated September 29, 2022


    Legal entities will be able to buy securities of issuers from unfriendly states without any restrictions, regardless of whether they have the status of a qualified investor or not.
    Updated September 29, 2022


    The Bank of Russia extended for six months restrictions on the withdrawal of money abroad. The restrictions will be in effect from October 1, 2022 to March 31, 2023.
    Updated September 29, 2022


    Recommendations of the Bank of Russia on the fulfillment of obligations on credits (loans) in foreign currency.
    Updated September 24, 2022


    The Central Bank has published recommendations for credit institutions on repayment of loans in "unfriendly" currencies by borrowers.
    Updated September 23, 2022


    The Bank of Russia recommended banks and MFIs to give credit holidays to mobilized citizens.
    Updated September 21, 2022


    The Bank of Russia has decided to extend for one quarter (until January 1, 2023) the ban on credit institutions from disclosing certain information on public resources.
    Updated September 16, 2022


    The Bank of Russia cuts key rate by 50 bp to 7.50% p.a.
    Updated September 16, 2022



    Russian banks will have to indicate the minimum guaranteed rate on deposits from October 1.
    Updated September 15, 2022



    The Bank of Russia explained the nuances of real estate transactions with foreigners from friendly countries.
    Updated September 13, 2022<



    The Bank of Russia has prepared answers to frequently asked questions of self-regulatory organizations and associations of financial market participants regarding executive orders of the President of the Russian Federation aimed at ensuring financial stability.
    Updated September 12, 2022



    The Moscow Exchange has expanded the list of shares not available to non-residents.
    Updated September 9, 2022



    The Central Bank has allowed banks to give clients cash from foreign currency accounts and deposits credited from 9 September in roubles at the bank's exchange rate.
    Updated September 8, 2022


    Bank of Russia announced the appearance of unified registers of investors in 2023.
    Updated September 6, 2022


    Bank of Russia to limit sales of securities issued by unfriendly countries to non-qualified investors.
    Updated September 6, 2022


    The Bank of Russia clarifies the requirements for the application of the "C" account regime for the purposes of the performance of obligations to non-residents.
    Updated August 24, 2022


    Moscow Stock Exchange intends to admit non-residents from unfriendly countries to the stock market, allowing them to trade in negotiated transactions mode (a special mode available only to professional traders).
    Updated August 25, 2022


    The Central Bank listed the advantages of a “deal with the regulator” for violating insiders.
    Updated August 15, 2022


    Central Bank clarified the decree on the suspension of banks' operations in "toxic currency".
    Updated August 9, 2022


    Brokers and management companies will be responsible for the trusted identification of non-residents.
    Updated August 8, 2022


    Russian President Vladimir Putin signed a decree on a temporary procedure for fulfilling obligations under bank account contracts in foreign currency and obligations under bonds issued by foreign entities.
    Updated August 8, 2022


    The Central Bank has extended restrictions on foreign currency cash withdrawals for six months, until March 9, 2023. The limit may not exceed 10,000 US dollars or an equivalent amount in euros.
    Updated August 1, 2022


    The interest rate on preferential investment loans for industry in Moscow has been reduced from 9% to 3%. In addition, the size of the loan to be provided is increased from 1bn RUB to 3bn RUB.
    Updated July 27, 2022


    Previous updates

    Disclaimer
    The information above is intended solely for usage by the reader who accepts full responsibility for respective consequences. The information provided is general and should not be considered as the opinion of AEB, as well as business, legal, tax, accounting, consulting, or any other professional advice. In all cases, you should consult with professionals familiar with your factual situation for advice concerning specific matters before making any decisions. AEB is not liable and will not accept any responsibility concerning any action or abstention from action related to respective information.