Sanctions against Russia and Regulatory updates in Ukraine and Russia


Please see below the latest information on sanctions adopted as a response to Russia’s aggression against Ukraine, as well as regulatory updates in Ukraine and Russia that may have an impact on EU companies.

1. EU sanctions and guidance

On 21/04, the EU sanctioned two more individuals in relation to the illegal annexation of Crimea.

Over the past days, the EU announced that several countries (North Macedonia, Montenegro, and Albania, Bosnia and Herzegovina, Iceland, Liechtenstein, and Norway, members of the European Economic Area, as well as Ukraine and Georgia) have aligned with a number of restrictive measures adopted by the EU.

Finally, here you can find all the updated guidance regarding the implementation of EU sanctions. The most recent FAQs were published today and include: Central securities depositories, Maritime Safety, and Intellectual Property Rights.


2. UK sanctions and measures to support Ukraine

On 25/04, the UK announced new trade measures to support Ukraine. These include:

• Cutting tariffs on all goods from Ukraine to zero under the UK-Ukraine FTA
• A new export ban on products and technology that Russia could use to repress the people of Ukraine.

Tariff measures, which are part of broad UK economic support to Ukraine, include £1bn in loan guarantees. More information may be accessed here.

On 26/04, the UK added two individuals to its sanctions list, subject to asset freezes, and updated its consolidated lists overall.


3. U.S. measures on export controls – useful summary and guidance

The U.S. Department of Commerce, Bureau of Industry and Security (B.I.S), published a useful summary of all the measures adopted by the U.S. in the area of export controls, including guidance.

4. Regulatory update – Ukraine

Legislative draft Nr. 7279 (submitted on 12/04) proposes to introduce criminal liability for performing operational management of Ukraine-based subsidiaries of international companies.

In particular, the draft law proposed to introduce criminal liability for the following actions by executive officers of Ukraine-based international companies:

• Executing instructions, guidelines, and other management directive actions issued in the framework of relationship of economic control as defined by Ukrainian antitrust legislation, by natural persons-citizens of Russia, or by management officers of legal persons, registered in Russia;
• Executing actions on behalf and in the interest of natural persons-citizens of Russia or legal persons, registered in Russia, or natural persons sentenced in accordance with Ukrainian criminal law in connection with crimes related to Russia-related economic activities.


5. Regulatory update – Russia

On 25/04, a draft law regulating the status of a foreign agent was submitted to the Russian Duma.

The draft law formulates such notions as “foreign agent” and “foreign influence”:
• A “foreign agent” is a person “who has received support and (or) is under foreign influence in other forms” and carries out activities described as political; purposeful collection of information in the field of military and military and technical activities of Russia; distribution of messages and materials intended for an unlimited range of persons, and participation in the creation of such messages and materials.
• Foreign influence implies providing a person with support from a foreign source (e.g., a foreign state, its authorities, international organizations), influencing that person, “including through coercion, persuasion,” and by other means.
• Foreign support refers to the receipt of foreign funding, organizational, methodological, scientific, and technical assistance, and assistance in other forms.
• The norm that allows the classification of a foreign agent without having foreign funding or other types of assistance, but, for example, as a result of the “impact” of a foreign source will be further extended to all categories of foreign agents (including foreign media agents).
• Moreover, the bill proposes the creation of a unified register of foreign agents. The Ministry of Justice will state on what basis a person was recognized as a foreign agent.
• The bill also introduces a unified procedure for exclusion from the register. A foreign agent can be excluded from the register if an unscheduled inspection by the Ministry of Justice finds that the foreign agent did not receive foreign funding/assistance and was not engaged in activities described in the bill.
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