New UK Sanctions: The UK announced a new tranche of restrictions on June 22, 2022, which became effective on Thursday, June 23, 2022.  As summarized on the UK government’s website, the latest prohibitions include the following:

Export Restrictions

Prohibitions on the export, supply and delivery, making available and transfer (as well as related technical assistance, financial services, funds and brokering services) of:

  • internal repression goods and technology, including firearms, certain vehicles, explosive substances, and other equipment designed for personal protection to or for use in non-government controlled Ukrainian territory;
  • goods and technology relating to chemical and biological weapons to or for use in non-government controlled Ukrainian territory;
  • maritime goods and technology for use on a Russia-flagged vessel;
  • additional oil refining goods and technology to Russia; and
  • additional critical industry goods and technology to Russia.

Prohibitions on the export to, or for use in, Russia, of jet fuel and fuel additives (as well as related technical assistance, financial services, funds, and brokering services).

Prohibitions on the export to, or for use in, Russia, of Sterling (GBP) or EU-denominated banknotes.  The regulations include an exception for the personal use of such banknotes for someone traveling to Russia, but only up to £10,000.

Import Restrictions

Prohibitions on the import, acquisition or supply and delivery of goods as enumerated in the regulations that originate in or are consigned from Russia (as well as related technical assistance, financial services, funds, and brokering services).  Classification codes of these goods are also included.  The prohibited goods include caviar, certain chemical compounds, fertilizers with specific elements, and certain turbojets and gas turbines, among others.

Additional Services Restrictions

In addition to the bans listed above, prohibitions on the provision of technical assistance, and financial services, funds, and brokering services, relating to iron and steel imports.

Potential Future EU Sanctions: During this week’s European Union summit, the European Council reaffirmed that “the work on sanctions will continue, including efforts to strengthen implementation and prevent circumvention”.  According to media reports, EU officials are identifying potential sectors to be targeted next for sanctions.  Media reports indicate gold, an important asset to the Russian Central Bank, is being considered future restrictions.

Proposed Russian Oil Price Cap: On June 20, 2022, U.S. Treasury Secretary Janet Yellen said publicly that the U.S. and other allies are discussing capping the price of Russian oil by potentially exempting insurance for Russian oil, which is currently prohibited by the EU.  “We are talking about price caps or a price exception that would enhance and strengthen recent and proposed energy restrictions by Europe, the United States, the U.K. and others that would push down the price of Russian oil and depress Putin’s revenues while allowing more oil supply to reach the global market,” Secretary Yellen said.  This plan, for example, could allow buyers to keep their insurance on the condition that they do not pay more than a set amount for the oil.  EU member states are reportedly skeptical of the proposal as it would require unanimous consent.