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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Sanctions overview

International Sanctions

  • EU SANCTIONS

    ASSET FREEZES  

    Since February 23, 2022, the Council of the European Union has imposed an asset freeze and a prohibition from making funds available to the following individuals and entities:
    • VEB.RF (a.k.a Vnesheconombank) 
    • Internet Research Agency 
    • Bank Rossiya 
    • Promsvyazbank 
    • Gas Industry Insurance Company SOGAZ 
    • 336 individuals involved in the Russian government decision to recognize the Donetsk and Luhansk regions (members of the Russian State Duma); 
    • 48 individuals accused of supporting, implementing or benefiting from actions that undermine the territorial integrity, sovereignty, independence and stability of Ukraine (including, inter alia, members of the management and supervisory bodies of VEB.RF, VTB Bank, Promsvyazbank, Rosneft and Transneft and shareholders of Alfa Bank); 
    • 99 individuals, including members of the Russian National Security Council accused of having supported Russia's recognition of the Donetsk and Luhansk regions or of having facilitated Russia's military action from Belarus, as well as additional members of the Russian State Duma who ratified the government decisions of the "Treaty of Friendship, Cooperation and Mutual Assistance" between Russia and the Donetsk and Luhansk regions. These recent designations include Russia's President Vladimir Putin and Russia's Minister of Foreign Affairs Sergey Lavrov.
    • 22 high ranked members of Belarus’ military armed forces accused for their role in the decision making and strategic planning processes that led to the Belarusian involvement in the Russian aggression against Ukraine.
    • 14 additional oligarchs and prominent businesspeople involved in key economic sectors providing a substantial source of revenue to the Russian Federation - notably in the metallurgical, agriculture, pharmaceutical, telecom and digital industries -, as well as their family members. 
    • 146 members of the Russian Federation Council, who ratified the government decisions of the ‘Treaty of Friendship, Cooperation and Mutual Assistance between the Russian Federation and the Donetsk People's Republic’ and the ‘Treaty of Friendship, Cooperation and Mutual Assistance between the Russian Federation and the Luhansk People’s Republic’.

    On March 15, were targeted oligarchs Roman Abramovich and German Khan as well as Alexander Shokhin, President of RSPP and other prominent businesspeople involved in key economic sectors, such as iron and steel, energy, banking, media, military and dual use products and services. The list also includes people from the media sphere, such as Konstantin Ernst (CEO of Channel One Russia). Were also added companies in the aviation, military and dual use, shipbuilding and machine building sectors such as Rosneft Aero and JSC Rosoboronexport.

    On April 8 were targeted an additional 217 individuals and 18 entities including high-ranking Kremlin officials, oligarchs, other prominent businesspeople involved in key economic sectors such as energy, finance, media, defence and arms industry. The list also includes family members of already sanctioned individuals, in view of the fact that they are benefiting from the regime or to prevent the circumvention of EU sanctions.  These designations include among others:
    • Maria Vladimirovna Vorontsova and Ekaterina Vladimirovna Tikhonova, the daughters of Russian President Vladimir Putin
    • German Gref
    • Moshe Kantor
    • Boris Rotenberg 
    • Oleg Deripaska
    • Alexander Shulgin
    • Ministers and the members of the ‘People’s Council’ of the so-called ‘Donetsk People’s Republic’ and ‘Luhansk People’s Republic’ are also blacklisted
    • Bank Otkritie
    • Novikombank
    • Sovcombank
    • VTB
    As of 15 March 2022, the restrictive measures “in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine”, apply to a total of 877 individuals and 62 entities and include an asset freeze and a prohibition from making funds available to the listed individuals and entities. In addition, a travel ban applicable to the listed persons prevents these from entering or transiting through EU territory.

    As of 8 April 2022, the restrictive measures “in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine”, apply to a total of 1091 individuals and 90 entities and include an asset freeze and a prohibition from making funds available to the listed individuals and entities. In addition, a travel ban applicable to the listed persons prevents these from entering or transiting through EU territory.


    RUSSIAN FINANCIAL SECTOR AND CAPITAL MARKETS  

    On 23 February 2022, the Council of the European Union decided to introduce a sectoral prohibition to finance the Russian Federation, its government and Central Bank through:
    • A prohibition on purchasing, selling or otherwise dealing with transferable securities and money-market instruments issued after 9 March 2022 by (i) Russia and its government, (ii) the Russian Central Bank or (iii) entities / bodies acting on behalf / at the direction of the Russian Central Bank; and 
    • A prohibition on making / being part of arrangements to make any new loans or credits after 23 February 2022 to (i) Russia and its government, (ii) the Russian Central Bank or (iii) entities / bodies acting on behalf / at the direction of the Russian Central Bank (without any maturity limits for loans / credit applying in this context).

    On 25 February 2022, the Council of the European Union significantly extended the existing sanctions relating to the financial sector by 
    • cutting Russian access to the most important capital markets;
    • prohibiting the listing and provision of services in relation to shares of Russian state-owned entities on EU trading venues;
    • introducing new measures which significantly limit the financial inflows from Russia to the EU, by prohibiting the acceptance of deposits exceeding certain values from Russian nationals or residents, the holding of accounts of Russian clients by the EU Central Securities Depositories, as well as the selling of euro-denominated securities to Russian clients. 
    Overall, these sanctions target 70% of the Russian banking market, and key state-owned companies, including in the field of defense.

    More particularly: in addition to the existing sectoral sanctions applying to Sberbank, VTB Bank, Gazprombank, Vnesheconombank (VEB), Rosselkhozbank, OPK Oboronprom, United Aircraft Corporation, Uralvagonzavod, Rosneft, Transneft and Gazprom Neft, it is now prohibited to purchase, sell, provide investment services for or assistance in the issuance of, or otherwise deal with any transferable securities and money-market instruments issued by those entities (or by non-EU entities more than 50% owned by them or by entities acting on their behalf / at their direction) after 12 April 2022 (without any maturity threshold applying). 

    The same prohibition applies to the following entities (and to non-EU entities more than 50% owned by them and to entities acting on their behalf / at their direction): 
    • Alfa Bank 
    • Bank Otkritie 
    • Bank Rossiya 
    • Promsvyazbank 
    • Almaz-Antey 
    • Kamaz 
    • Novorossiysk Commercial Sea Port 
    • Rostec (Russian Technologies and State Corporation) 
    • Russian Railways 
    • JSC PO Sevmash 
    • Sovcomflot 
    • United Shipbuilding Corporation 
    There is also a new prohibition on making or being part of any arrangement to make a new loan or credit to any of the aforementioned entities (or to non-EU entities more than 50% owned by them or entities acting on their behalf / at their direction) – again without any maturity threshold applying. This restriction applies as of 26 February 2022. 

    On 9 March 2022, the Council clarified the notion of “transferable securities” so as to clearly include crypto-assets, and thus ensure the proper implementation of the sectoral restrictions in place. 

    On 15 March 2022, the Council of the European Union decided to fully prohibit any transactions with 12 Russian State-owned enterprises, across different sectors, more particularly from the military-industrial complex. The list includes:
    • OPK Oboronprom
    • United Aircraft Corporation
    • Uralvagonzavod
    • Rosneft
    • Transneft
    • Gazprom Neft
    • Almaz-Antey
    • Kamaz
    • Rostec (Russian Technologies State Corporation)
    • JSC Po Sevmash
    • Sovcomflot
    • United Shipbuilding Corporation

    On 15 March 2022, the Council decided to prohibit the provision of any credit rating services, as well as access to any subscription services in relation to credit rating activities, to any Russian person or entity. 

    On 8 April 2022, the Council introduced the additional following measures:
    • A full transaction ban and asset freeze on four Russian banks (Bank Otkritie, Novikombank, Sovcombank, and VTB) representing 23% of market share in the Russian banking sector. After being de-SWIFTed these banks will now be subject to an asset freeze, thereby being completely cut off from EU markets.
    • A prohibition on providing high-value crypto-asset services to Russia.
    • A prohibition on providing advice on trusts to wealthy Russians.


    BELARUSSIAN FINANCIAL SECTOR  

    On 9 March, the Council adopted additional sectoral measures targeting the Belarusian financial sector.
    The agreed measures:
    • restrict the provision of specialised financial messaging services (SWIFT) to Belagroprombank, Bank Dabrabyt, and the Development Bank of the Republic of Belarus, as well as their Belarusian subsidiaries;
    • prohibit transactions with the Central Bank of Belarus related to the management of reserves or assets, and the provision of public financing for trade with and investment in Belarus;
    • prohibit the listing and provision of services in relation to shares of Belarus state-owned entities on EU trading venues as of 12 April 2022;
    • significantly limit the financial inflows from Belarus to the EU, by prohibiting the acceptance of deposits exceeding €100.000 from Belarusian nationals or residents, the holding of accounts of Belarusian clients by the EU central securities depositories, as well as the selling of euro-denominated securities to Belarusian clients;
    • prohibit the provision of euro denominated banknotes to Belarus;
    • clarify the notion of “transferable securities” so as to clearly include crypto-assets, and thus ensure the proper implementation of the sectoral restrictions in place.


    CENTRAL BANK OF RUSSIA  

    On 28 February 2022, the Council adopted measures against the Central Bank of Russia. Transactions related to the management of reserves as well as of assets of the Central Bank of Russia, including transactions with any legal person, entity or body acting on behalf of, or at the direction of, the Central Bank of Russia, are prohibited.
    The competent authorities may authorize a transaction provided that it is strictly necessary to ensure the financial stability of the Union as a whole or of the Member State concerned.


    RUSSIAN AIRLINE CARRIERS  

    On 28 February 2022, the Council adopted a decision requiring all Member States to deny permission to land in, take off from, or overfly, their territories to any aircraft operated by Russian air carriers, including as a marketing carrier, to any Russian-registered aircraft, and to non-Russian-registered aircraft which are owned or chartered, or otherwise controlled by a Russian legal or natural person.
    Derogations may be given only for humanitarian purposes.


    ENERGY SECTOR  

    On 25 February 2022, the Council of the EU prohibited the sale, supply, transfer or export to Russia of specific goods and technologies in oil refining and introduced restrictions on the provision of related services.

    On 25 March 2022, the Council introduced new restrictive measures which comprise a far-reaching ban on new investment across the Russian energy sector, with limited exceptions for civil nuclear related activities and the transport of certain energy products back to the EU. As per the Regulation, thefollowing activities fall under this ban: 
    • the exploration, production, distribution within Russia or mining of crude oil, natural gas or solid fossil fuels, the refining of fuels, the liquefaction of natural gas or regasification;
    • the manufacture or distribution within Russia of solid fossil fuel products, refined petroleum products or gas;
    • the construction of facilities or installation of equipment for, or the provision of services, equipment or technology for, activities related to power generation or electricity production.
    It also introduces a comprehensive export restriction on equipment, technology and services for the energy industry. Possible exemptions can be given by Member States for such exports if technologies are important for the supply of coal, gas or oil to the European Union, if they are destined to be used by an entity jointly or solely controlled by a legal person created under EU law or for the urgent prevention or mitigation of an event likely to have a serious and significant impact on human health and safety or the environment. 
     
    On 8 April 2022, the Council introduced a prohibition to purchase, import or transfer coal and other solid fossil fuels into the EU if they originate in Russia or are exported from Russia, as from August 2022.


    IRON AND STEEL SECTOR  

    On 15 March, 2022, the Council introduced an EU import ban on iron and steel products originated from Russia or exported from Russia. Increased import quotas will be distributed to other third countries to compensate.


    TRANSPORT SECTOR  

    On 25 February 2022, the Council of the EU introduced an export ban covering goods and technology in the aviation and space industry, as well as a prohibition on the provision of insurance and reinsurance and maintenance services related to those goods and technology. The EU also prohibited the provision of related technical and financial assistance.

    On 28 February 2022, the Council adopted a decision requiring all Member States to deny permission to land in, take off from, or overfly, their territories to any aircraft operated by Russian air carriers, including as a marketing carrier, to any Russian-registered aircraft, and to non-Russian-registered aircraft which are owned or chartered, or otherwise controlled by a Russian legal or natural person.
    Derogations may be given only for humanitarian purposes.

    On 8 April 2022, the Council adopted the following measures:
    • A prohibition to provide access to EU ports to vessels registered under the flag of Russia. Derogations are granted for agricultural and food products, humanitarian aid, and energy.
    • A ban on any Russian and Belarusian road transport undertaking preventing them from transporting goods by road within the EU, including in transit. Derogations are nonetheless granted for a number of products, such as pharmaceutical, medical, agricultural and food products, including wheat, and for road transport for humanitarian purposes.


    TECHNOLOGY SECTOR  

    On 25 February 2022, the EU imposed further restrictions on exports of dual-use goods and technology, as well as restrictions on exports of certain goods and technology which might contribute to Russia’s technological enhancement of its defence and security sector.
    This includes products such as semiconductors or cutting-edge technologies.


    MARITIME NAVIGATION GOODS AND RADIO COMMUNICATION TECHNOLOGY  

    On 9 March 2022, the Council introduced further restrictive measures with regard to the export of maritime navigation goods and radio communication technology to Russia. 
    By virtue of this decision, it will be prohibited to sell, supply, transfer or export, directly or indirectly, maritime navigation goods and technology to any natural or legal person, entity or body in Russia, for use in Russia, or for the placing on board of a Russian-flagged vessel.


    LUXURY GOODS SECTOR  

    On 15 March 2022, the Council introduced an EU export ban on luxury goods. These products are prohibited from being sold to both individuals and legal entities in Russia or "for use in Russia". 
    The restriction applies to luxury goods that cost more than €300 per item, unless otherwise specified in the document. The ban does not apply to goods needed for "official purposes", for diplomatic missions in Russia, international organizations and their employees.The list of goods prohibited for import includes among others:
    • Vehicles, with the exception of ambulances, for transporting people by land, air or water worth more than €50 thousand, as well as spare parts for them. The measure applies to passenger cars, including racing cars, and motorcycles;
    • Wines, including sparkling, beer and spirits;
    • Home appliances including hair dryers, microwaves, coffee makers and kettles, as well as smartphones and game consoles;
    • Electronic devices for recording video or sound worth more than €1,000, including cameras;
    • Caviar and its substitutes;
    • Truffles and their products;
    • Cigars and cigarillos;
    • Perfumes and cosmetics;
    • Watches, including wristwatches, and parts for them;
    • Musical instruments worth more than €1.5 thousand;
    • Works of art, collectibles and antiques;
    • Clothes, shoes and accessories (regardless of what material they are made of) and leather bags;


    EXPORT BANS  

    On 25 February 2022, the EU imposed further restrictions on exports of dual-use goods and technology, as well as restrictions on exports of certain goods and technology which might contribute to Russia’s technological enhancement of its defence and security sector.
    This includes products such as semiconductors or cutting-edge technologies.

    On 9 March 2022, the Council introduced further restrictive measures with regard to the export of maritime navigation goods and radio communication technology to Russia. 
    By virtue of this decision, it will be prohibited to sell, supply, transfer or export, directly or indirectly, maritime navigation goods and technology to any natural or legal person, entity or body in Russia, for use in Russia, or for the placing on board of a Russian-flagged vessel.

    On 8 April 2022, the Council introduced further targeted export bans:
    • in areas in which Russia is vulnerable due to its high dependency on EU supplies. This includes, for example, quantum computing, advanced semiconductors, sensitive machinery, transportation and chemicals. It also includes specialist catalysts for use in the refinery industry.
    • jet fuel and fuel additives, which may be used by the Russian army


    IMPORT BANS  

    On 8 April 2022, the Council introduced import bans – worth €5.5 billion - including cement, rubber products, wood, spirits (including vodka), liquor, high-end seafood (including caviar), and an anti-circumvention measure against potash imports from Belarus. 


    EXCLUDING RUSSIA FROM PUBLIC CONTRACTS AND EUROPEAN MONEY; LEGAL CLARIFICATIONS AND ENFORCEMENT  

    • Full prohibition on the participation of Russian nationals and entities in procurement contracts in the EU. Limited exceptions may be granted by the competent authorities where there is no viable alternative.
    • Restriction on financial and non-financial support to Russian publicly owned or controlled entities under EU, Euratom and Member State programmes. For instance, further to measures previously announced in research and education, the Commission will terminate participation in all ongoing grant agreements to Russian public bodies or related entities, and suspend all related payments, under Horizon 2020 and Horizon Europe, Euratom, and Erasmus+. No new contracts or agreements with Russian public bodies or related entities will be concluded under these programmes.
    • Addressing various overlaps between export restrictions on dual-use items and advanced technologies and other provisions.
    • Extending to all official EU currencies the prohibitions on the export of banknotes and on the sale of transferrable securities.


    VISA POLICY  

    Diplomats, other Russian officials, and business people will no longer be able to benefit from visa facilitation provisions, which allow privileged access to the EU. This decision will not affect ordinary Russian citizens. The decision will enter into force on the day of the adoption. 


    FOR FURTHER INFORMATION AND FAQs  

    You may also find further information on the dedicated webpages developed by the European Commission, proving information on the EU sanctions adopted against Russia: 

    There is a dedicated mailbox created by the Commission, where questions and feedback are collected - EC-RUSSIA-SANCTIONS@ec.europa.eu. The input and any prioritisation that stakeholders will be able to give to the questions will allow DG FISMA to respond quicker and provide more specific guidance, that is better tailored to the challenges that businesses are currently confronted.
    Following the adoption of Council Regulation (EU) 2022/355(3) banning the imports of steel products originating in Belarus and  Council Regulation (EU) 2022/428(4) banning the imports of certain steel products originating in Russia, the Commission has decided to adjust the functioning of the safeguard measures to ensure that these import bans do not create a shortage of supply in the Union market in the categories affected, and that Union steel users can continue sourcing those volumes from other sources. In annex you can find the legal text that amends the existing safeguards. The text that was published on 16.03 enters into force on 17.03.2022. 

  • US SANCTIONS

    FINANCE  

    On February 21, the U.S. President signed an Executive Order Blocking Property Of Certain Persons And Prohibiting Certain Transactions With Respect To Continued Russian Efforts To Undermine The Sovereignty And Territorial Integrity Of Ukraine which prohibits new investments, trade and financing in the so-called Donetsk and Luhansk People’s Republics (DNR and LNR) in response to their recognition by the Russian Federation as “independent” states. 

    On February 22, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) published a package of additional Russia-related sanctions. 
    First, OFAC published Russia-related Directive 1A under Executive Order 14024 imposing additional restrictions on Russian sovereign debt. This action extends existing sovereign debt prohibitions to cover participation in the secondary market for bonds issued after March 1, 2022 by the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation. 
    Second, OFAC sanctioned two major Russian state-owned financial institutions Vnesheconombank (VEB) and Promsvyazbank (PSB) as well as 42 of their subsidiaries by adding them to the list of Specially Designated Nationals (SDN).
    As part of the designation of PSB, OFAC also took action against five vessels that are owned by PSB Lizing OOO, a designated subsidiary of PSB. All five vessels were identified pursuant to E.O. 14024 as blocked property in which PSB Lizing OOO has an interest.
    OFAC also issued two Russia-related general licenses General License 2 and General License 3 authorizing certain servicing transactions and the wind down of transactions involving Vnesheconombank.

    On February 24, the U.S. Treasury took additional restrictive measures against Russia’s top financial institutions, by sanctioning Russia’s two largest banks Sberbank and VTB Bank as well as almost 90 financial institution subsidiaries around the world. Treasury also sanctioned additional Russian elites and their family members and imposed additional new prohibitions related to new debt and equity of major Russian state-owned enterprises and large privately owned financial institutions. 

    1. Sanctions on Russia’s major financial institutions
    Treasury took action against Russia’s two largest financial institutions, Public Joint Stock Company Sberbank of Russia (Sberbank) and VTB Bank Public Joint Stock Company (VTB Bank). It additionally imposed blocking sanctions on three additional major Russian financial institutions: Bank Otkritie, Novikom Bank, and Sovcom Bank.
     
    This directive prohibits U.S. financial institutions from:
    the opening or maintaining of a correspondent account or payable-through account for or on behalf of any entity determined to be subject to the prohibitions of the Russia-related CAPTA Directive, or their property or interests in property; and
    the processing of transactions involving any such entities determined to be subject to the Russia-related CAPTA Directive, or their property or interests in property. Accordingly, U.S. financial institutions must reject such transactions unless exempt or authorized by OFAC.
    Pursuant to Directive 2 under E.O. 14024, Sberbank and 25 Sberbank foreign financial institution subsidiaries that are 50 percent or more owned, directly or indirectly, by Sberbank were identified in Annex 1 to the Russia-related CAPTA Directive. These subsidiaries include banks, trusts, insurance companies, and other financial companies located in Russia and six other countries. Sberbank and other affiliated entities determined to be subject to the Russia-related CAPTA Directive have been added to OFAC’s List of Foreign Financial Institutions Subject to Correspondent Account or Payable-Through Account Sanctions (CAPTA List), a reference tool that provides actual notice of OFAC actions with respect to foreign financial institutions for which the opening or maintaining of a correspondent account or a payable-through account in the United States is prohibited or subject to one or more strict conditions. All foreign financial institutions owned 50 percent or more, directly or indirectly, by Sberbank are covered by the prohibitions of the Russia-related CAPTA Directive, even if not identified on OFAC’s CAPTA List. 
     
    OFAC has also imposed full blocking sanctions on VTB Bank. VTB Bank was designated pursuant to E.O. 14024 for being owned or controlled by, or for having acted or purported to act for or on behalf of, directly or indirectly, the Government of the Russian Federation, and for operating or having operated in the financial services sector of the Russian Federation economy. In addition, 20 VTB Bank subsidiaries were designated pursuant to E.O. 14024 for being owned or controlled by, directly or indirectly, VTB Bank. These subsidiaries include banks, holding companies, and other financial companies located in Russia and eight other countries. All entities owned 50 percent or more, directly or indirectly, by VTB Bank are subject to blocking, even if not identified by OFAC. 
     
    2. Debt and equity prohibitions against major state-owned and private entities
    OFAC expanded Russia-related debt and equity restrictions to additional key aspects of Russia’s economy. To implement this action, OFAC issued Directive 3 under E.O. 14024, “Prohibitions Related to New Debt and Equity of Certain Russia-related Entities” (the “Russia-related Entities Directive”) to prohibit transactions and dealings by U.S. persons or within the United States in new debt of longer than 14 days maturity and new equity of Russian state-owned enterprises, entities that operate in the financial services sector of the Russian Federation economy, and other entities determined to be subject to the prohibitions in this directive. This includes 13 entities with outstanding debt issuances, six of which are also subject to certain debt or additional restrictions pursuant to directives under E.O. 13662. 
     
    Pursuant to E.O. 14024, OFAC identified the following 11 Russian entities as being owned or controlled by, or having acted or purposed to act for or on behalf of, directly or indirectly, the Government of the Russian Federation:
    Sberbank
    Gazprombank Joint Stock Company
    Joint Stock Company Russian Agricultural Bank
    Public Joint Stock Company Gazprom
    Public Joint Stock Company Gazprom Neft
    Public Joint Stock Company Transneft(Transneft)
    Public Joint Stock CompanyRostelecom 
    Public Joint Stock CompanyRusHydro 
    Public Joint Stock CompanyAlrosa 
    Joint Stock CompanySovcomflot 
    Open Joint Stock CompanyRussian Railways 
    Pursuant to E.O. 14024, OFAC identified the following three Russian entities for operating or having operated in the financial services sector of the Russian Federation economy:
    Joint Stock Company Alfa-Bank 
    Credit Bank of Moscow Public Joint Stock Company
    Sberbank
     
    3. General Licences
    OFAC has also issued several general licenses in connection with these actions, in particular Russia-related General License 5General License 6General License 7General License 8General License 9General License 10General License 11, and General License 12
    These eight general licenses authorize certain transactions related to:
    international organizations and entities;
    agricultural and medical commodities and the COVID-19 pandemic;
    overflight and emergency landings;
    energy;
    dealings in certain debt or equity;
    derivative contracts;
    the wind down of transactions involving certain blocked persons; and
    the rejection of transactions involving certain blocked persons.

    On February 28, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) prohibited United States persons from engaging in transactions with the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation. This action effectively immobilizes any assets of the Central Bank of the Russian Federation held in the United States or by U.S. persons, wherever located. 

    On March 3, the Department of the Treasury's Office of Foreign Assets Control (OFAC) issued Russia-related several General Licenses, allowing the continuation of certain activities that would otherwise be prohibited under the new sanctions. A number of these general licenses are time-limited.. In addition, OFAC has published new Frequently Asked Questions and updated several Frequently Asked Questions.
    Related documents:

    On March 24 OFAC published Frequently Asked Question №1,029 "How do the prohibitions of Executive Order (E.O.) 14024 and other Russia-related sanctions impact gold-related transactions or persons participating in the gold market?" 
    In addition, OFAC issued Russia-related General License 6AGeneral License 17AGeneral License 20, and Ukraine-/Russia-related General License 25

    On April 1 OFAC designated 21 entities and 13 individuals as part of an effort to target Russia’s sanctions evasion networks and technology companies, which are instrumental to the Russian Federation’s military operation.
    OOO Serniya Engineering (Serniya) 
    Majory LLP, Photon Pro LLP
    OOO Robin Treid 
    Invention Bridge SL 
    AO NII-Vektor 
    T-Platforms 
    Joint Stock Company Mikron 
    Molecular Electronics Research Institute (MERI) 

    On April 6 the US Treasury imposed full blocking sanctions on Sberbank, Russia’s largest state-owned bank, and Alfa-Bank, Russia’s largest private bank. All entities owned 50 percent or more, directly or indirectly, by Sberbank and Alfa Bank are blocked under E.O. 14024, even if not designated by OFAC.
    In addition, pursuant to E.O. 14024, Treasury is designating 42 Sberbank subsidiaries and 6 Alfa Bank subsidiaries for being owned or controlled by, or for having acted or purported to act for or on behalf of, directly or indirectly, Sberbank and Alfa Bank, a person whose property and interests in property are blocked pursuant to E.O. 14024.
    OFAC is also identifying five vessels owned by Alfa-Lizing OOO as blocked property: products tanker Lady Leila (IMO 9683740), chemical/oil tanker Lady Rania (IMO 9784893), products tanker Lady Sevda (IMO 9683738), general cargo vessel Sv Konstantin (IMO 9203710), and general cargo vessel Sv Nikolay (IMO 9482926).
     
    Also President Biden issued E.O. of April 6, 2022, “Prohibiting New Investment in and Certain Services to the Russian Federation in Response to Continued Russian Federation Aggression,” to ban all new investment in the Russian Federation by U.S. persons, wherever located, as well as the export, reexport, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, of any category of services as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State, to any person located in the Russian Federation. 
    A new Executive Order was issued, which bans new investment in the Russian Federation and the provision of certain services to any person located in the Russian Federation by U.S. persons, wherever located.

    The Department of the Treasury's Office of Foreign Assets Control (OFAC) has issued Russia-related:
    General License 8B, Authorizing Transactions Related to Energy, 
    General License 9B, Authorizing Transactions Related to Dealings in Certain Debt or Equity,
    General License 10B, Authorizing Certain Transactions Related to Derivative Contracts,
    General License 21, Authorizing the Wind Down of Sberbank CIB USA, Inc.,
    General License 22, Authorizing the Wind Down of Transactions Involving Public Joint Stock Company Sberbank of Russia and 
    General License 23,  Authorizing the Wind Down of Transactions Involving Joint Stock Company Alfa-Bank. 
    General License 26, Authorizing the Wind Down of Transactions Involving Joint Stock Company SB Sberbank Kazakhstan or Sberbank Europe AG.

    On April 8 OFAC designated Alrosa, a Russian state-owned enterprise (SOE) and the world’s largest diamond mining company, which is also responsible for 90 percent of Russia’s diamond mining capacity. The Department of State also redesignated Joint Stock Company United Shipbuilding Corporation (USC), as well as its subsidiaries and board members. 

    On April 19, the United States Department of the Treasury's Office of Foreign Assets Control (OFAC) issued a Fact Sheet for "Preserving Agricultural Trade, Access to Communication, and Other Support to Those Impacted by Russia's operationin Against Ukraine." This fact sheet outlines that Americans can engage in transactions related to agricultural and medical exports, the work of nongovernmental organizations (NGOs), COVID-19 relief, humanitarian assistance and telecommunications and internet services to support the free flow of information. OFAC also authorized transactions necessary for certain activities, including for humanitarian projects in Russia and Ukraine, by NGOs despite U.S. sanctions on Moscow by issuing Russia-related General License 27 "Certain Transactions in Support of Nongovernmental Organizations' Activities." 


    INDIVIDUALS  

    On February 22, 2022, the U.S. imposed sanctions against certain Russian elites, by designating Denis Bortnikov (son of the director of the FSB Alexander Bortnikov), Petr Fradkov (son of former Russian Prime Minister Mikhail Fradkov), and Vladimir Kiriyenko (son of the first deputy head of the Presidential Administration Sergey Kiriyenko).

    On February 24, 2022, the U.S. imposed sanctions against certain Russian elites, by designating the following individuals:
    Sergei Sergeevich Ivanov, son of Sergei Borisovich Ivanov
    Andrey Patrushev, son of Nikolai Platonovich Patrushev
    Ivan Igorevich Sechin, son of Igor Ivanovich Sechin
    Alexander Aleksandrovich Vedyakhin (Vedyakhin) is First Deputy Chairman of the Executive Board of Sberbank
    Andrey Sergeyevich Puchkov (Puchkov) VTB Bank
    Yuriy Alekseyevich Soloviev (Soloviev) VTB Bank and his wife Galina Olegovna Ulyutina

    On February 25, the U.S. Treasury imposed sanctions on President of the Russian Federation Vladimir Putin and the Minister of Foreign Affairs, Sergei Lavrov, as well as other members of Russia’s Security Council and added those individuals in its list of Specially Designated Nationals. 

    On March 3 some Russian individuals and entities have been added to OFAC's Specially Designated Nationals List (SDN list). 
    Among them, are sanctioned numerous Russian elites and their family members, with the blocking of certain of these persons' property, and  Russian intelligence-directed disinformation outlets. In addition to sanctioning elites, OFAC designated 26 Russia- and Ukraine-based individuals and seven Russian entities "in connection with the Russian Government's efforts to promulgate disinformation and influence perceptions."
     
    More particularly have been designated:
    Alisher Usmanov
    Nikolay Tokarev
    Igor Shuvalov
    Dmitry Peskov
    Pavel Prigozhin
    Boris Rotenberg
    Strategic Culture Foundation
    News Agency "Inforos"
    Media outlet "NewsFront"
    Media outlet "SouthFront"
     
    The assets of the designated individuals or entities are blocked and U.S. persons are generally prohibited from dealing with them. 

    On March 24 OFAC has added the following individuals and entities to its list of Specially Designated Nationals (SDN list):
    48 Russian companies that are part of Russia’s defense-industrial base and that produce weapons that have been used in the special military operation in Ukraine;
    328 members of the Russian State Duma, who supported the signature of the treaties recognizing the self-proclaimed independence of the so-called Donetsk People’s Republic (DNR) and Luhansk People’s Republic (LNR);
    as well as Herman Gref, the head of Sberbank.
    The assets of the designated individuals or entities are blocked and U.S. persons are generally prohibited from dealing with them. This action aligns with similar actions taken by the European Union, the United Kingdom, and Canada.

    On April 20, OFAC designated 29 individuals and 40 legal entities from Russia for their “attempts to evade sanctions imposed by the United States and its international partners on Russia”. The sanctions list includes the first deputy chairman of the Central Bank of Russia, Ksenia Yudaeva, Russian oligarch Konstantin Malofeyev and the chairman of the board of Otkritie Bank, Mikhail Zadornov. Sanctions were also imposed on the Tsargrad media group and PJSC Transcapitalbank. 
    In addition OFAC has issued Russia-related General License 28 and General License 29.


    EXPORT  

    On February 24 the U.S. Commerce Department, through its Bureau of Industry and Security (BIS), implemented a series of stringent export controls that will restrict Russia’s access to technologies and other items. BIS’s Russia-specific export control measures impose a policy of denial on sensitive items Moscow relies on for its defense, aerospace, and maritime industries. These items, many of which were not previously subject to controls when destined for Russia, include semiconductors, computers, telecommunications, information security equipment, lasers, and sensors.  The rule also imposes stringent controls on 49 Russian military end users, which have been added to BIS’s Entity List. 

    On 8 March 2022, President Biden signed a new Executive Order (E.O.) "Prohibiting Certain Imports And New Investments With Respect To Continued Russian Federation Efforts To Undermine the Sovereignty And Territorial Integrity Of Ukraine" to ban the import of Russian oil, liquefied natural gas, and coal to the United States.
     
     . SCOPE OF THE NEW E.O.
    The new E.O. bans:
    • The importation into the United States of Russian crude oil and certain petroleum products, liquefied natural gas, and coal. 
    • New U.S. investment in Russia’s energy sector.
    • Americans will also be prohibited from financing or enabling foreign companies that are making investment to produce energy in Russia.
     
    2. PUBLICATION OF GENERAL LICENSE 16 AND NEW FAQs
    Following President's Biden announcement, the U.S. Treasury released one General License and several Frequently Asked Questions to aid in the wind-down of deliveries of existing purchases that have already been contracted for.
     
    More specifically, Treasury issued: 
    Most importantly, according to FAQ 1018, to the extent the import of such products of Russian Federation origin outside of the United States does not involve a sanctioned person or an otherwise prohibited transaction, non-U.S. persons are not exposed to sanctions under E.O. of March 8, 2022

    On 11 March 2022, President Biden signed a new Executive Order (E.O.) "on Prohibiting Certain Imports, Exports, and New Investment with Respect to Continued Russian Federation Aggression". The new E.O. bans:
    - the importation into the United States of Russian fish, seafood, and preparations thereof; alcoholic beverages; non-industrial diamonds;
    - the exportation of luxury goods from the United States to the Russia Federation;
    - new investment in any sector of the Russian Federation economy.
    - the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, of U.S. dollar-denominated banknotes to the Government of the Russian Federation or any person located in the Russian Federation;
    Related documents:

    On March 13, the U.S. Commerce Department’s Bureau of Industry and Security (BIS) published a detailed list of luxury items that will be prohibited from being imported into Russia from March 16, 2022. The list includes about 570 commodity items (at the level of the ten-digit code of the American commodity nomenclature), among others:
    • alcohol (champagne, whiskey, bourbon, tequila, rum, etc.);
    • tobacco products (cigars, pipe tobacco, snuff and chewing tobacco, etc.);
    • cosmetics and perfumery (eau de toilette, makeup products, skin care products, etc.);
    • handbags, suitcases;
    • fur skins, natural fur products, silk, carpets;
    • certain clothing and garments, certain footwear (sweaters, trousers, ski suits, swimwear, gloves, ties, etc., if the US wholesale price is over $1,000 per item);
    • precious stones and jewelry;
    • marine engines, snowmobiles, motorcycles, some passenger cars, including electric vehicles;
    • concert pianos, wristwatches, art objects, etc.

    On March 18, the Department of the Treasury's Office of Foreign Assets Control (OFAC) has issued Ukraine-/Russia-related General License 24 regarding transactions related to the provision of maritime services. In addition, OFAC has amended one Frequently Asked Question on possible prohibition with dealing in Kazakh-origin crude oil of the Caspian Pipeline Consortium (“CPC”). It confirms that the importation prohibition of E.O. 14066 applies to the import of certain products of Russian Federation origin to the United States and excludes imports that are not of Russian Federation origin, even if such items transit through or depart from the Russian Federation. 

    On April 1 the US Department of Commerce has added 120 entities from Russia and Belarus to its Entity List, hence banning the export of U.S. products to those organizations related, in particular, to the defense sector.
     
    From Belarus, the list includes 24 organizations, from Russia - 95, as well as one individual:
    JSC Almaz
    JSC "ElectroSignal"
    JSC Informakustika
    I. Alikhanov Institute for Theoretical and Experimental Physics
    Institute for High Energy Physics
    JSC "Moscow Research Institute of Communications"
    JSC Chelyabinsk Radio Plant Polet
    JSC Research and Production Enterprise Salyut
    JSC Elektrotyaga is a part of Tactical Missiles Corporation JSC. In addition to Elektrotyaga, 34 other structures included in the KTRV were also subject to restrictions.

    On April 9, 2022, the U.S. Department of Commerce, through the Bureau of Industry and Security (BIS), issued a final rule that expands its highly restrictive controls on the export and reexport of U.S. -origin and certain foreign-produced commodities, software, and technologies to Russia and Belarus. As a result of the rule issued, BIS has imposed highly restrictive license requirements on all categories of items on the Commerce Control List (CCL) to Russia and Belarus, which expands U.S. scrutiny of transactions to almost any sensitive dual-use technology, software, or commodities. Furthermore, by applying a policy of denial to applications involving these items, the U.S. is effectively cutting off Russia and Belarus from access to a range of items.  Specifically, the rule expands the license requirements on Russia and Belarus to all items designated on the CCL. The rule imposes new license requirements for items including certain comp

  • 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 23.05.2022



    By plane:

    - Afghanistan | Kabul 
    - Armenia | Yerevan 
    - Azerbaijan | Baku 
    - Bahrain | Manama
    - Egypt | Cairo, Hurghada, Sharm El Sheikh
    - Ethiopia | Addis Ababa
    India | Delhi
    - Iran | Tehran
    - Israel | Tel Aviv
    - Kazakhstan | Almaty, Aktobe, Nur-Sultan, Kostanay, Shymkent, Taldykorgan, Ust'-Kamenogorsk, Zhezkazgan
    Kyrgyzstan | Bishkek
    Carrier: https://www.aero.kg/
    Qatar | Doha
    Carrier: https://www.qatarairways.com/en-am/homepage.html
    - Serbia | Belgrad
    Sri Lanka | Colombo
    - Turkey | Istanbul or Antalya
    - UAE | Abu Dhabi, Dubai or Sharjah 
    - Uzbekistan | Tashkent 



    By bus or private car:

    - Estonia - Russia 
    - Finland - Russia
    - Latvia - Russia
    - Lithuania - Russia (Kaliningrad region)
    - Poland - Russia (Kaliningrad region)
    - Latvia - Belarus 
    - Lithuania - Belarus
    - Poland - Belarus




    By train:

    Kazakhstan - 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.

  • Finance and payments

    On foreign exchange controls under external sanctions pressure
    Updated 06.05.2022

    Suspend until 31 December 2022 the tax authorities' inspections of compliance with the currency legislation of the Russian Federation, inclusive, except in cases where the inspections revealed violations, the limitation period for administrative liability for which expires before 31 December 2022. Suspension of inspections does not apply, in particular, to violations related to fulfillment of regulatory acts adopted as of February 28, 2022 providing for special economic measures. In addition, the draft extended from 1 June 2022 to 1 December 2022 the deadline for individuals to submit reports on the movement of funds and other financial assets on accounts (deposits) in foreign banks for the reporting year 2021.


    The Bank of Russia has lowered its key rate
    Updated 06.05.2022

    While prices growth is slowing down, the Central Bank of Russia has reduced its key rate by 3 p.p., to 14% per annum. Strengthening of the ruble and lower inflationary expectations helped soften the policy. However, according to the estimates of the Bank of Russia, this year's inflation rate may reach 23%.


    A draft decree on additional measures to ensure Russian organizations' foreign trade activity settlements
    Updated 06.05.2022

    According to the draft, residents participating in foreign economic activities are entitled to receive foreign currency and/or RF currency in cash for transferred goods from non-residents under foreign trade contracts providing for export of goods. The funds received are to be imported into the territory of the Russian Federation and subsequently credited to the resident's bank account in an authorised bank. Thereafter, the resident will be obliged to carry out the obligatory sale of the foreign currency within the terms and to the extent stipulated in paragraph 2 of Decree No 79 of 28 February 2022.


    Vladimir Putin signed the decree on counter-measures
    Updated 06.05.2022

    Russian President Vladimir Putin has signed a decree that will introduce counter-measures against countries and legal entities that have committed "unfriendly acts." According to the text of the decree, federal public authorities, other state bodies, local authorities, organizations and individuals under the jurisdiction of Russia are prohibited: 
    • to enter into transactions (including foreign trade contracts) with persons under sanctions; 
    • fulfill obligations to sanctioned individuals under completed transactions, if the obligations have not been fulfilled or not fulfilled in full; 
    • carry out financial transactions that benefit sanctioned persons. 
    The Central Bank of Russia has been empowered to give official clarifications on this issue. It also introduces a ban on the export outside of Russia of products and raw materials, the production and extraction of which are carried out in the country, if they are supplied to the benefit of persons under sanctions, or by persons under sanctions - to third parties. Vladimir Putin instructed the Russian government to approve the list of sanctioned persons within 10 days.


    Decree on the temporary procedure for fulfilment of financial obligations in the sphere of corporate relations to foreign creditors
    Updated 06.05.2022

    • According to the document, if a Russian company distributes profits, residents from countries classified as "unfriendly" will receive their share in "C" bank accounts. Money from such accounts can be used for a limited number of purposes. 
    • LLCs, partnerships and cooperatives that are Russian residents will pay non-resident participants from unfriendly countries (or controlled by residents of such countries) a share of profits, same was as Decree No. 95 previously established for lenders from unfriendly countries. Russian residents can apply to a Russian bank to open a C-type account in the name of the foreign participant and transfer there their share of the profits in roubles. 
    • The Central Bank and Finance Ministry will also be able to determine a different procedure for such payments. 
    • The decree also grants them the power to authorise individual companies to pay out profits in foreign currency in circumvention of this procedure. The new procedure will not affect real estate transactions, including participation in shared construction, or the purchase by a resident of a hostile country of less than 25% of the voting shares of a Russian resident.


    The government has approved the Ministry of Economic Development's draft law on early repurchase of property from the lessor in case of an increase in lease payments
    Updated 06.05.2022

    It is noted that redemption in full or in part is possible if the leasing agreement was concluded before 1 March and the payment has either already increased or will increase by the end of the year. The fee will not exceed 1% of the redemption price. The entrepreneur will not face any penalties or fines for premature termination of the contract. The leasing company will not run the risk of recognising the leasing agreement as an instalment sale transaction. A clarification to this effect will be issued by the Ministry of Economic Development jointly with the Federal Tax Service and the Ministry of Finance as soon as the law is adopted.


    The Bank of Russia introduces rules for sale of investment products through banks
    Updated 22.04.2022

    Banks will be required to inform their clients about the specifics and risks of investment products, as well as that returns on them are not guaranteed and investments are not insured by the state deposit insurance system.



    Bank of Russia extends measures to ease foreign exchange control for all exporters
    Updated 21.04.2022

    Now, all exporters have the right to carry out the mandatory sale of their foreign currency earnings credited to their accounts with authorized banks on and after 19 April 2022 in the amount established by Executive Order of the President of the Russian Federation No. 79, dated 28 February 2022, within 60 business days from the date of their crediting to transit foreign currency accounts with authorized banks. Earlier, the foreign currency sale period was extended from three to 60 business days for non-energy commodity exports. The permit is valid until 1 September 2022, however, it can be adjusted if the situation in the financial market changes.



    Grace period for banks in FPS extended for another two years
    Updated 20.04.2022

    The Bank of Russia Board of Directors has decided to extend the zero fee period for banks on P2P money transfers in the Faster Payments System (FPS) until 1 July 2024.



    The government has introduced new requirements for banks on mortgage loans
    Updated 19.04.2022

    The government has introduced new requirements for banks on mortgage loans. Banks will be required to disclose the full cost of the mortgage loan and inform the borrower about the price of the loan, including insurance and other additional services.



    UIFs for private investors: new rules
    Updated 19.04.2022

    The Bank of Russia has established requirements for the rules of trust management of open-end, closed-end, exchange-traded and interval unit investment funds (UIFs) for non-qualified investors.In particular, the new rules will help investors better understand which fund to choose: if an asset is mentioned in the name of a UIF, then at least 80% of the fund's property should be invested in this asset.Furthermore, unit holders of all UIFs will be able to receive dividends on the units and pay for the units not only with money but also with other assets, e.g., with securities they own.



    A bill to amend the Federal Law "On Joint-Stock Companies" and Article 8 of the Federal Law "On the Securities Market"
    Updated 18.04.2022

    The purpose of the bill is to develop a mechanism for regulating problems with shareholders whose information is missing and who do not exercise their shareholder rights for an extended period of time (hereinafter, "lost shareholders"). The bill establishes the conditions and procedure for suspending the sending to individuals and legal entities whose rights to shares are recorded in a company's shareholder register of notices of general meetings of shareholders or absentee voting, voting ballots and other information, as well as for suspending the payment of dividends on outstanding shares.


    The Duma has passed a law banning the placement and circulation on foreign stock exchanges of depositary receipts for shares of Russian issuers: Russian companies and banks traded abroad will have to undergo delisting and convert the receipts into shares
    Updated 18.04.2022

    The law will be enacted from the date of its official publication, while the ban on Russian depositary receipts traded abroad will take effect 10 days after that. Russian issuers will have five working days to terminate depository receipt agreements and the same number of days to notify the CBR, attaching supporting documentation. All decisions related to the termination of depositary receipts on foreign exchanges will be made by the head of the company, and no approval of the board of directors or shareholders' meeting will be required.


    Clarification from the Central Bank on ruble transfers to foreign accountss
    Updated 17.04.2022

    As of 1 March, Russians are prohibited from transferring foreign currency to their accounts with banks and other financial institutions outside the country; this rule does not apply to transfers in roubles, the Central Bank has clarified. Russians can transfer money in roubles to their accounts in foreign banks, which can then be converted and credited to their account in a foreign bank or transferred to another person's account in a foreign bank. These rules apply to residents and non-residents from non-sanctioned countries as well as to non-residents from all other countries working in Russia underemployment or civil law contracts.


    Foreign exchange control under foreign trade contracts eased for more industries
    Updated 17.04.2022

    The Bank of Russia has decided to cancel the 30% limit on advance payments under foreign trade contracts for the provision of travel, building and equipment renovation and maintenance services. It will also be possible to make full advance payments under contracts for exhibition services provided by non-residents from friendly countries or for non-residents’ services in organizing exhibitions, fairs, and congresses in friendly countries. Earlier, the 30% limit on advance payments was canceled for foreign trade contracts in transport and for a number of contracts worth up to 15,000 US dollars.


    On eurobond payments
    Updated 13.04.2022

    The Subcommittee of the Governmental Commission for the Control of Foreign Investments agreed with the proposals of the Ministry of Finance of Russia and the Bank of Russia to terminate the issuance of permits for making payments on Eurobonds in the manner prescribed by the issue documentation.


    The Bank of Russia Board of Directors decided to cut the key rate by 300 basis points to 17.00% per annum
    Updated 11.04.2022

    External conditions for the Russian economy are still challenging, considerably constraining economic activity. Financial stability risks are still present, but have ceased to increase for the time being, including owing to the adopted capital control measures. This decision reflects a change in the balance of risks of accelerated consumer price growth, decline in economic activity and financial stability risks. In its further key rate decisions, the Bank of Russia will take into account risks posed by external and domestic conditions and the reaction of financial markets, as well as actual and expected inflation dynamics relative to the target and economic developments over the forecast horizon, and holds open the prospect of further key rate reduction at its upcoming meetings. The Bank of Russia informs.


    The Bank of Russia has relaxed the temporary procedure for cash currency transactions
    Updated 11.04.2022

    Citizens who had opened foreign currency accounts or deposits before March 9, 2022, and who have not yet chosen the established limit on the withdrawal of cash currency from their accounts, will be able to get not only dollars, but euros in cash from April 11, 2022. The overall withdrawal limit of $10,000 or the equivalent in euros will remain in effect until September 9. Citizens will still be able to receive funds in rubles from foreign currency accounts in excess of the limit during the interim order. In addition, the Bank of Russia resumes the ability for banks to sell foreign currency to citizens from April 18, 2022, but only the currency received at banks' cash offices from April 9, 2022.



    The Bank of Russia softens the rules for buying and selling foreign currency through brokers and banks
    Updated 11.04.2022

    From April 11, 2022, the commission for the purchase of currency through brokers, which was previously set at 12%, is cancelled. Also, from April 11, 2022, the Bank of Russia is canceling the requirement for banks to limit the difference in the currency buying and selling rate, with the exception of importing legal entities. The regulator recommends that banks set for importers who purchase foreign currency to pay for import contracts an exchange rate spread of no more than 2 rubles from the exchange rate.


    The State Duma passed in the second, main reading a bill prohibiting banks from applying certain prohibitive tariffs in order to combat money laundering and cash-out.
    Updated 07.04.2022

    The ban applies only to increased rates when terminating or changing a contract - the bank's fee must not be higher than the normal fee it charges for transfer transactions. Federal Law #115-FZ dated August 7, 2001 "On counteraction to legalization (laundering) of proceeds of crime and financing of terrorism" will contain the clause that additional or increased commission fees charged by banks are not related to anti-money laundering or anti-cashing measures.


    Clarification of the Bank of Russia on the application of the provisions of Presidential Decrees: N 79 of 28 February 2022 and N 95 of 5 March 2022, concerning the compulsory sale of foreign currency and the temporary procedure for Russian debtors of their obligations to foreign creditors.
    Updated 07.04.2022

    According to the Presidential Decree № 79 dated 28.02.2022, mandatory sale of part of foreign currency earnings is carried out under all foreign trade contracts providing for the transfer of goods, works for them, services for them, transfer of information and results of intellectual activities, including exclusive rights to them, regardless of the fact of contract registration in accordance with the requirements established by the CBR instruction № 181-I dated 16.08.2017. All types of foreign currency without exception are subject to compulsory sale. Performance of obligations under foreign trade export contracts is possible by crediting funds of non-residents to bank accounts in authorized banks or without crediting funds to bank accounts in authorized banks in cases stipulated by Article 19 of Law No. 173-FZ of 10.12.2003. Residents - participants of foreign economic activity are obliged to sell the obligatory part of currency proceeds under all foreign trade export contracts. Foreign trade contracts providing for the export of goods from the Russian Federation include only the proceeds received from a non-resident under contracts concluded between a resident and a non-resident and providing for the purchase and sale of goods. Authorized banks as currency control agents control the residents' compliance with the requirement for the mandatory sale of currency earnings. According to Presidential Decree No. 95 of 05.03.2022 "On Temporary Priority of Obligations to Certain Foreign Creditors", the State Corporation for Development VEB.RF has the right to conduct some banking operations in accordance with the legislation. The provisions of Decree No. 95 applicable to the activities of Russian credit institutions apply to VEB.RF as well.


    The Board of Directors of the Bank of Russia has established a "K" type bank account regime for gas settlements with customers from unfriendly countries.
    Updated 05.04.2022

    Decree No. 172 of the President of the Russian Federation dated March 31, 2022. Gas customers will be able to open "K" type bank accounts in rubles and foreign currencies. Payments under gas contracts will be credited to the foreign currency account. The bank will then sell this currency on the exchange and credit the funds received to the ruble account, and then from this account the rubles will be transferred to the accounts of Russian gas suppliers.


    Currency control rules for foreign trade contracts in the field of transport and small businesses have been relaxed
    Updated 02.04.2022

    The Bank of Russia has decided to cancel the 30% limit on advance payments for a number of contracts with non-residents for services, works, transfer of information and results of intellectual activities.

    Restrictions have been removed for such contracts up to $15 thousand. Advance payment in full for services rendered will also be possible under foreign trade contracts for transportation of goods, other transportation services, logistics and use of transport infrastructure.

    The introduced easing will improve the conditions for foreign economic activity for Russian companies, including small and medium businesses.

    Payment amounts are calculated at the official rate of the Bank of Russia on the date of the contract.


    Bank of Russia eases restrictions on the transfer of funds abroad for individuals 
    Updated 02.04.2022

    The Bank of Russia has set new thresholds on the amount of funds transfers abroad for individuals over the next six months. During a calendar month, individuals have the right to transfer no more than $10,000 or the equivalent in another currency from their account in a Russian bank to their account or another individual abroad in the Russian Federation. No more than $5,000 or the equivalent in another currency can be transferred per month through companies providing money transfer services without opening an account.



    Bank of Russia introduces temporary procedure for foreign cash transactions for legal entities and individual entrepreneurs from 10 March to 10 September 2022  
    Updated: 10.03.2022

    During the effective period of the temporary procedure for foreign cash transactions, resident legal entities and resident individual entrepreneurs may receive cash in US dollars, Japanese yen, British pounds, and euros in the amount not exceeding 5,000 US dollars and only to cover expenses for foreign business trips. In certain cases, banks may request the regulator to increase this amount. 

    As regards any other currencies, resident legal entities and resident individual entrepreneurs may receive cash on the grounds provided for by Russian laws, without any restrictions, at the market exchange rate as of the withdrawal date.

    During the effective period of the temporary procedure for foreign cash transactions, non-resident legal entities and non-resident individual entrepreneurs are not allowed to receive cash in US dollars, Japanese yen, British pounds, and euros. As to any other currencies, non-residents may receive funds from their accounts without any restrictions, at the market exchange rate as of the withdrawal date. 

    All other terms and conditions of deposits and accounts in US dollars, euros, British pounds, and Japanese yen opened by legal entities and individual entrepreneurs as of 10 March 2022 remain unchanged.




    All payment cards issued by Russian banks continue to operate as normal  
    Updated: 09.03.2022

    The international payment systems Visa and MasterCard discontinue operation in Russia since 10 March. This means that the payment cards of these systems issued by Russian banks will operate as normal in Russia, but will no longer operate abroad and in foreign online stores. Apple Pay and Google Pay will also become unavailable.

    All Visa and MasterCard payment cards will continue to operate as normal in Russia until the expiry dates specified on the cards. Customers can carry out all usual transactions without any restrictions, including payments for goods and services, cash deposits and withdrawals at ATMs, and card-to-card transfers.

    Many banks have already announced that they will extend the effective period of these cards. After that, banks will reissue Mir cards for their customers. There is no need to block Visa and MasterCard payment cards before their expiry dates and issue Mir cards to replace them.

    Mir cards allow all transactions available with the cards of the international payment systems. Customers can also connect to the Mir Pay service on Android OS smartphones. Mir cards are accepted in Turkey, Vietnam, Armenia, Belarus, Kazakhstan, Kyrgyzstan, Tajikistan, Uzbekistan, South Ossetia, and Abkhazia.




    Clarifications by the Bank of Russia on the application of the Decree of the President of the Russian Federation of February 28, 2022, № 79 "On application of special economic measures in relation to unfriendly acts of the United States of America and foreign states and international organizations joining them"  
    (Please note this information is an unofficial translation provided by the AEB. In case of any controversial readings please refer to the original documents in Russian.)
    Updated: 04.03.2022 


    From March 1, 2022, may the Russian banks use their correspondent accounts opened with the banks located outside the territory of the Russian Federation? 
    The ban on the transfer of funds in foreign currency to their accounts opened with banks located outside the territory of the Russian Federation does not apply to Russian credit institutions. 

    Is there a ban on transactions that involve the receipt by a resident of foreign currency in the form of repayment of a loan by a non-resident, or payment by a non-resident of interest (penalties) and other payments provided for by the loan agreement? 
    From this March 1, 2011, only transfer of funds in foreign currency to non-residents under the newly concluded loan agreements or under the existing on this date loan agreements are prohibited. Transfer of monetary funds in foreign currency to non-residents under the existing loan agreements concluded before March 1 of this year shall be subject to immediate termination. At the same time currency operations on receipt by the residents of the foreign currency in fulfillment of their obligations under the contracts of credit earlier given by the residents to non-residents are not limited (including operations on repayment by the non-residents of the credit, payment by the non-residents of the sums of interest and (or) penalties under such credit). 

    Whether there is a ban on transactions related to fulfillment of obligations by residents under loan agreements providing for extension of a loan by a non-resident to a resident. 
    Residents are not restricted from performing their obligations to non-residents under loan agreements providing for extension of a loan by a non-resident to a resident. 

    Is it possible for residents to buy goods abroad, pay for services, including those related to utility payments for real estate located abroad, pay for education and medical services? 
    The Decree does not prohibit residents (individuals and legal entities, sole proprietors, persons engaged in private practice and "self-employed" persons) from making payments in favor of non-residents both in the currency of the Russian Federation and in foreign currency for the above purposes. 

    How is the amount of foreign currency received from non-residents from January 1, 2022, with respect to which the obligatory sale of foreign currency proceeds by a resident participating in foreign trade activities is provided for? 
    The calculation of 80% of the amount of foreign currency subject to compulsory sale is made by a resident participating in foreign trade activities independently of the amount of the foreign currency balance in the accounts (including transit currency accounts, settlement accounts, deposit accounts) of the resident participating in foreign trade activities as of February, 28 2022, and received from export activities in the period from January 1 to February 28, 2022. To confirm that such balance of foreign currency is export revenue, the said resident shall provide the authorized bank with the information substantiating the balance of export revenue in the account(s) of the resident - participant in foreign economic activity, confirmed, inter alia, by statements of account(s). 

    Does the compulsory sale of part of foreign currency proceeds apply to foreign currency that was received from January 1, 2022, but was deposited by a resident as of February 28, 2022? 
    The requirement for compulsory sale of a portion of foreign currency proceeds applies also to such foreign currency funds on deposit. 

    At what rate is the compulsory sale of part of foreign currency proceeds carried out? 
    There are no special requirements regarding the rate of compulsory sale of part of foreign currency earnings. Currently, such sale is carried out at the market rate. Residents are free to choose any method of such sale envisaged by legislation. 

    Is it possible to sell foreign currency earnings by installments?
    Compulsory sale of foreign currency earnings is possible by installments, provided that all 80 percent of the sum of foreign currency that is subject to compulsory sale is sold within 3 working days from the date of crediting under Paragraph 2 of the Decree. 

    What types (names) of foreign currencies are subject to compulsory sale. 
    At present, we are talking about the mandatory sale of a portion of foreign currency proceeds received from non-residents in any type (denomination) of foreign currencies. 

    How do the requirements of the decree on obligatory sale of a part of currency proceeds correlate with the requirements of other legislative acts, in particular, those providing preferences (benefits) for residents of the Special Economic Zone (for example, for residents of the Kaliningrad region)? 
    The obligation to sell the foreign currency proceeds introduced since the February 28, 2022, applies also to the residents-participants of foreign economic activity of the Special Economic Zone in the Kaliningrad region. 

    Should credit institutions perform control of transactions performed by clients and refuse to perform a client's order in case of detection of transfer by a client of funds in foreign currency to his account opened in banks and other financial market institutions located outside the territory of the Russian Federation? 
    Credit institutions that are currency control agents are obliged to monitor currency operations conducted by their clients for legality and refuse to perform illegal currency operations.

  • Support measures

    Presidential decisions  

    Anti-crisis package of measures to support citizens and businesses
    A number of measures concern the production and purchase of medicines and medical devices. The Government will be able to decide on the restrictions on the export from Russia of medical products imported from the countries that "made a decision to impose restrictive economic measures against the Russian Federation". The procedure for procurement of medical drugs and products has been simplified. 
    In order to develop the production of medical goods that do not have Russian analogues, the government will be able to establish "peculiarities of licensing of pharmaceutical activities", production of medicines and maintenance of medical products. They can be purchased from a single supplier, but it must not be from the countries that have imposed sanctions against Russia.

    Measures to ensure socio-economic stability  
    Regional Governors are instructed to "take comprehensive measures" to ensure socio-economic stability. Such measures include, in particular:
    preserving the availability of social services;
    uninterrupted functioning of life support facilities, transport, social infrastructure, health care, communications, and so on;
    implementation of additional measures aimed at eliminating increased demand for certain types of goods.

    The Air Code has been amended to allow Russian airlines to retain a fleet of foreign aircraft and allow them to operate on domestic routes
    Law on measures to support civil aviation. It allows registering the rights to foreign aircraft leased by domestic companies. Also airliners will be given Russian airworthiness certificates.


    Governmental decisions  

    The list of sectors for granting credit vacations to small and medium-sized businesses. The list includes agriculture, science, education, health, culture, hospitality, sports, catering, information technology, wholesale and retail trade, services - in total more than 70 codes OKVED (Classifier of Economic Activities).

    The list of goods not subject to the ban on export outside the territory of the Russian Federation is extended.
    This list includes, in particular, goods produced in free warehouses located in Russia with the use of goods placed under the customs procedure of a free warehouse.
    The list of certain types of goods subject to a temporary ban on export was adjusted and the authorization procedure for the export of certain types of goods was clarified. 
    Finally, a list of certain types of medical goods, in respect of which a temporary permit-based export procedure is introduced, is established, and the cases to which the ban on export of certain types of goods does not apply, are specified.
     
    Sanctions-affected industrial companies may receive a grace period for fulfilling their obligations under subsidy agreements
    Sanctions-affected enterprises will receive state support within the state programs "Development of Industry and Increase of its Competitiveness", "Development of Aviation Industry", "Development of Electronic and Radio-Electronic Industry", "Development of Shipbuilding and Technology for Offshore Fields Development", "Development of Pharmaceutical and Medical Industry" and "Scientific and Technological Development of the Russian Federation". 

    The Russian government has extended by two years the deadline for the performance of obligations under subsidy agreements for exporting companies under the national project "International Cooperation and Export" affected by sanctions. 

    Automatic extension by 12 months of the validity of licenses and other types of permit and their simplified obtainment or re-issuance in 2022. The measure will affect more than 120 types of permits, including agriculture, industry, retail trade (including trade in excisable goods), communication services, cab services.

    Credit vacations
    The Government has determined the parameters of loans for citizens to apply for "credit vacations". It established the maximum amounts of loans for which citizens have the right to apply to banks for the provision of "credit vacations".

    Moratorium on business inspections will remain effective in Russia until the end of 2022
    Scheduled inspections will be retained only in relation to a limited list of objects of control, within the framework of sanitary-epidemiological, veterinary and fire control, as well as industrial safety supervision.

      
    Other authorities’ decisions  

    The Bank of Russia has decided to temporarily set the maximum value of acquiring fees for the period from April 18 to August 31, 2022 at 1% for companies that sell socially important goods or provide such services. 

    The Federal Tax Service of Russia suspended inspections of compliance with currency legislation
    To reduce the administrative burden on organizations and citizens, the tax authorities suspend inspections of compliance with currency legislation in terms of violations under the Federal Law "On Currency Regulation and Control".

    The digital "Import Substitution Exchange" service  was created by the Ministry of Industry and Trade and the Ministry of Digital Development.
    The new service, based on the State Information System of Industry, allows the procurement of import-substituting goods of domestic production, analogues of sanctioned products and original goods produced in Russia. Customers will be able to publish requests for the purchase of goods, and suppliers will be able to send their price proposals and analogues without additional costs, approvals and intermediaries.
    Link to the platform:

    Subsidies for companies that hire people under 30
    State support in the form of subsidies to companies that hire people under the age of 30. Companies and organizations that hire young people in 2022 will be able to count on state support as part of a program to subsidize hiring.

    EAEU countries adopted joint measures to stabilize the economy in a short time frame
    A package of measures, consisting of 33 paragraphs, was adopted at a meeting of the EEU Council. The list of measures includes:
    Cancellation of import duties on 458 items.
    Expansion of the use of national currencies in mutual trade.
    Simplification of import procedures, including the use of copies of certificates of origin.

    Residents to transfer currency to their accounts in foreign banks to finance current activities
    According to the Ministry of Finance, residents will be able to transfer funds in foreign currency to their foreign accounts to finance current activities. At the same time, the volume of transfers should not exceed the amount of funding for the previous year.  It will be allowed to transfer the currency received from non-residents as wages, rent, coupons and dividends from securities, and other interest payments to their accounts in foreign banks.  Citizens will be able to transfer funds in foreign currency from their foreign accounts opened in foreign banks before March 1, 2022, to their other foreign accounts, information on which has been disclosed to the Russian tax authorities. 

    Moscow to expand SME support and to increase compensation for the cost of high-tech projects equipment up to 50%
    Moscow has expanded the programme of co-financing the expenditure on the purchase of equipment by entrepreneurs in the capital.  It is aimed at supporting the SMEs - participants of the Moscow innovative cluster that run the projects in the field of a science, the industry and information technologies. 
    The maximum amount of the aid is increased from 10 to 30 million rubles per organization. 
    From now on, when purchasing the equipment at their own expense or leasing it, the companies will be able to get reimbursement from Moscow City budget up to 50 percent of cost for domestic equipment (previously - up to 35 percent) and up to 35 percent of cost for foreign equipment (previously - up to 25 percent).
    Additionally, the program allows to compensate the interest rate on loans for working capital within the limits of the key rate of the Central Bank of Russia.



  • Experts’ analytics

     
    BOFIT | Trade sanctions and Russian production
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    In this brief overview, BOFIT examine the potential short-term effects of trade sanctions on Russian production with an input-output framework. More
     Morgan Lewis | Russia limits transactions with shares received upon cancellation of DR Programs
    05.05.2022 Morgan Lewis | Russia limits transactions with shares received upon cancellation of DR Programs
    The delisting of Russian issuers’ depositary receipts could potentially lead to a disproportional increase in sales of underlying shares in the Russian stock market. More
     Morgan Lewis |  Delisting of Russian issuers' depositary receipts - the end of an era?
    04.05.2022 Morgan Lewis | Delisting of Russian issuers' depositary receipts - the end of an era?
    A new federal law in Russia prohibits Russian issuers from having their shares traded outside Russia via depositary receipts. More
     Morgan Lewis | Nationalization of assets of persons associated with "Unfriendly Countries"
    14.04.2022 Morgan Lewis | Nationalization of assets of persons associated with "Unfriendly Countries"
    Russia has proposed amendments to Article 235 of the Russian Civil Code, which allows for the compulsory seizure of assets from persons from so-called "unfriendly states. If adopted, this law would create a framework that would allow for the nationalization of the assets of these individuals without compensation. More
     Morgan Lewis | Russia reintroduces insolvency moratorium
    13.04.2022 Morgan Lewis | Russia reintroduces insolvency moratorium
    An insolvency moratorium first introduced during the COVID-19 pandemic applies to nearly all Russian legal entities, individuals, and sole entrepreneurs, and bans the commencement of insolvency proceedings against Russian obligors. More

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