Russia Sanctions:  The U.S., EU, and UK continue to apply pressure on Russia through the implementation of additional sanctions.  The UK instituted the most significant additional sanctions this week, designating more than 350 persons.  The EU also prohibited engaging in transactions with an identified list of Russian state-owned companies and their subsidiaries outside of the EU, with limited exceptions.  This list includes Rosneft, Transneft, Gazprom Neft, and a number of military companies.  Many of the sanctions announced this week were targeted at the same entities and persons previously sanctioned by other jurisdictions.

Oligarch Sanctions:  The U.S. partnered with Australia, Canada, Germany, France, Italy, Japan, the United Kingdom, and the European Commission, to launch the Russian Elites, Proxies, and Oligarchs (REPO) multilateral task force.  The task force consists of the Finance Ministry and Justice or Home Ministry in each jurisdiction.  Its aim is to enhance coordination between the jurisdictions to enable information sharing that can lead to concrete actions.  The U.S. Department of Justice’s KleptoCapture task force will help support this effort.

Additionally, a number of additional oligarchs and prominent businesspeople were sanctioned this week.  The UK sanctioned more than 50 oligarchs, many of whom were previously designated by the U.S. or EU.  These included Petr Aven, Mikhail Fridman, German Khan, and Andrey Guryev.  The EU also sanctioned a handful of additional oligarchs including Roman Abramovich, German Khan, and Marina Sechina.

Export & Import Controls:  The U.S. prohibited “new investments in any sector of the Russian Federation economy” as determined by the Department of State and Treasury.  Using this authority, the U.S. prohibited the export of “luxury goods” to Russia.  The EU implemented a similar measure.  The two jurisdictions define luxury goods differently, but both prohibitions cover a large set of goods including everything from perfumes, to expensive cars, to clothing.  The U.S. also prohibited the export of U.S. dollar-denominated banknotes, but provided limited general licenses to authorize the export in some circumstances for U.S. persons, or activities for the personal maintenance of individuals located in Russia.

The U.S. also prohibited the importation of Russian-origin fish, seafood, alcoholic beverages, and non-industrial diamonds.  Additionally, the EU issued a general trade license permitting the provision of technical assistance, financial services and funds, and brokering services, related to vessels subject to recent regulations in some circumstances.

The U.S., EU, UK and G7 jointly announced an intention to revoke Russia’s “most favored nation” trading status, enabling increases on import duties.  In the U.S., the House of Representatives voted to strip Russia and Belarus of this status on March 17.  The measure will now move to the Senate.  The EU prohibited the import of Russian origin iron and steel products.

Energy Sector:  The EU issued additional restrictions around entities operating in the energy sector in Russia.  The regulation prohibits the acquisition or extension of participation in such entities, the provision of financing to such entities, or the creation of joint ventures with such entities.

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Photo of Caroline Brown Caroline Brown

Caroline E. Brown is a partner in Crowell & Moring’s Washington, D.C. office and a member of the firm’s White Collar & Regulatory Enforcement and International Trade groups and the steering committee of the firm’s National Security Practice. She provides strategic advice to…

Caroline E. Brown is a partner in Crowell & Moring’s Washington, D.C. office and a member of the firm’s White Collar & Regulatory Enforcement and International Trade groups and the steering committee of the firm’s National Security Practice. She provides strategic advice to clients on national security matters, including anti-money laundering (AML) and economic sanctions compliance and enforcement challenges, investigations, and cross border transactions, including review by the Committee on Foreign Investment in the United States (CFIUS) and the Committee on Foreign Investment in the U.S. Telecommunications Services Sector (Team Telecom).

Caroline brings over a decade of experience as a national security attorney at the U.S. Departments of Justice and the Treasury. At the U.S. Department of Justice’s National Security Division, she worked on counterespionage, cybersecurity, and counterterrorism matters and investigations, and gained unique insight into issues surrounding data privacy and cybersecurity. In that role, she also sat on both CFIUS and Team Telecom and made recommendations to DOJ senior leadership regarding whether to mitigate, block, or allow transactions under review by those interagency committees. She also negotiated, drafted, and reviewed mitigation agreements, monitored companies’ compliance with those agreements, and coordinated and supervised investigations of breaches of those agreements.