Responses to the Russia/Ukraine Crisis - Sanctions Update No. 9

Back in February 2022, when Russia commenced its full-scale invasion of Ukrainian territory, few would have thought that three years on, the fighting would be continuing. It is possible that negotiations will proceed and an end to the conflict on the ground may be in sight. Nonetheless, it seems unlikely that the vast, complicated and global structure of legal, financial and trade restrictions on Russian businesses, individuals and other related parties will be dismantled as a consequence.  

Indeed, the EU has recently introduced two fresh packages of sanctions  particularly targeting Russia’s so-called “shadow fleet” and strategically important sectors of the Russian economy, such as energy, transport, infrastructure and financial services. The UK has imposed new reporting obligations on a large number of additional business sectors and continues to designate individuals, entities and ships. In the last few months, the U.S. has expanded sanctions with regard to Russia’s energy sector, continued to designate actors that participate in Russia’s sanctions evasion network and prosecuted cases relating to U.S. export controls violations. European allies continue to apply pressure on the Russian economy, cutting off sources of revenue from oil, coal and other valuable products and limiting access to global funds. Other countries, including Switzerland, Australia, New Zealand, Canada and Japan, have adopted similar regimes.

However, it is clear that Russia is succeeding in evading sanctions and accessing trade and economic benefits from third party states, including Belarus, Iran, North Korea and, increasingly, China. The U.S., and to a lesser extent, the UK and EU, have imposed additional sanctions on these states as a result of their support of Russia, targeting in particular the provision of military equipment. The use of further secondary sanctions on such states would add another layer of legal technicality to be navigated by businesses and organisations operating in the global arena. 

In this our ninth update on the sanctions imposed on Russia and its allies by  the UK, EU and U.S. since February 2022, we leave aside recent political proposals and focus on the latest legal developments in sanctions regimes and their enforcement.