Russia Sanctions: As the war enters its fifth week, the U.S. and UK continue to expand the restrictions and add to the list of designated individuals and entities. Relative to sanctions and other prohibitions previously announced, there were few developments over the past week, but additional targeted sanctions may be forthcoming should the Russian invasion intensify.
UK Geographic-Based Restrictions: The UK extended its previous restrictions on Crimea to include “non-government controlled Ukrainian territory,” defined by cross-reference to the territories defined in Ukrainian law as being temporarily occupied, such as Donetsk and Luhansk. As a result, the new restrictions prohibit investments, exports, imports, and shipping in those areas. Many of the restrictions include a wind-down for activity carried out under a contract concluded (or executed) before February 23, 2022, and that is carried out (or completed) before May 24, 2022, (for certain financial services) or August 24, 2022 (for certain trade, infrastructure, and tourism services).
Expansion of U.S. Sanctions Authorities: This week, the U.S. expanded its Russia sanctions authorities to include the aerospace, marine, and electronics sectors of the Russian economy. This follows previous determinations with respect to the financial services, technology, and defense and related materiel sectors of the economy pursuant to section 1(a)(i) of Executive Order (E.O.) 14024. The determination permits the future imposition of sanctions on any individual or entity determined to operate or have operated in any of those sectors, but otherwise has no immediate effect.
List of Aircraft Violating U.S. Export Controls: A total of 73 aircraft were added to a list of those flown to Russia in violation of U.S. export controls. Services related to these aircraft, including within Russia, now must be specifically authorized by the U.S. government. In particular, refueling, maintenance, repair, or the provision of spare parts or services for the aircraft is otherwise prohibited. The list of aircraft is not exhaustive, and the restrictions apply automatically to any aircraft that are flown to Russia in violation of U.S. Export Administration Regulations (EAR).
Sanctions Evasion Networks: The U.S. and UK designated for asset freezes entities and individuals involved in evading sanctions to procure sensitive technology and dual-use equipment for Russia. In a press release, the U.S. described a multi-country network including companies in Russia, the UK, and Spain, which procured key equipment for the Russian government. The EU and Japan have also previously implemented export restrictions on some of the entities.
Technology Company Sanctions: To further restrict Russia’s access to Western technology, the U.S. imposed blocking sanctions on four Russian technology companies that are involved in software, hardware, and research.
Russian Media Sanctions: In the most recent round of sanctions, the UK targeted Russian media outlets and their leaders. Rossiya Segodnya and TV-Novosti were designated and are subject to an asset freeze. Other notable designations include the CEO of Gazprom-Media Holding, managing director of RT, and senior executive of Rossiya Television and Radio network.
UK Restrictions Related to Oligarchs: The UK also passed legislation that prohibits the maintenance of aircraft or ships that belong to sanctioned Russian oligarchs or their businesses.