Sanctions update including counter measures by Russia

Further to our previous sanctions updates we herewith provide a further update of recent sanctions developments:

Sanctions newsletter of 3 of March

Sanctions newsletter of 25 of February

European Union

Sanctions against Russia (Implementing Regulation 396/2022)

  • Export of marine navigation goods and radio communication technology is prohibited
  • 160 individuals have been added to EU:s asset freeze list which now comprises of 862 individuals and 53 entities

Sanctions against Belarus (Council Regulation 398/2022)

  • Three banks blocked from Swift (Belagroprombank, Bank Dabrabyt, and the Development Bank of the Republic of Belarus)
  • Transactions with Belarus Central Bank are prohibited
  • Services to state owned entities on EU trading venues are prohibited
  • Deposits by Belarusian nationals are prohibited
  • Transfer of Euro bank notes to Belarus is prohibited

United Kingdom

  • The following individuals have been added to UK:s asset freeze list:
    o Roman Abramovich who is owner of Chelsea FC and has stakes in steel giant Evraz and Norilsk Nickel
    o Oleg Deripaska who has stakes in En+ Group
    o Igor Sechin who is the Chief Executive of Rosneft
    o Andrey Kostin who is Chairman of VTB bank
    o Alexei Miller who is CEO of energy company Gazprom
    o Nikolai Tokarev who is president of the Russia state-owned pipeline company Transneft
    o Dmitri Lebedev who is Chairman of the Board of Directors of Bank Rossiya
    o 386 members of the State Duma

United States

  • Ban on import to the United States of Russian oil, LNG and coal
  • Ban on US investments in Russia’s energy sector
  • US persons are prohibited from financing or enabling foreign companies that are making investment to produce energy in Russia.

Reports from the media suggest there are ongoing discussions within the US administration to impose a more comprehensive ban on Russian goods.

Russian counter measures

It is difficult to obtain reliable information about actions taken by the Government of Russia partly because of poor access to Russian governmental websites. The below is a summary of our understanding of steps taken:

A list of Unfriendly states

A list of “unfriendly states” comprising of 48 countries including all EU member States and the United States has been issued

Currency control

Russian entities must sell 80 % of the foreign currency they have received as a result of supplying goods, works, services or intellectual property abroad from 1 January 2022. In addition, absent authorisation, Russian entities are prohibited from lending foreign currency to non-residents, placing foreign currency on the foreign accounts of such persons, as well as making payments through foreign processing systems without opening bank accounts.


Certain transactions involving the lending of roubles or dealings in real estate and securities and which involve Russian residents and legal entities which are either established in unfriendly states, doing significant business there or deriving significant profit therefrom, as well as entities controlled by entities meeting these conditions, need authorisation.

Payments by Russian debtors to foreign creditors

Certain payments involving credits, loans and financial instruments by Russian debtors towards foreign creditors in unfriendly states are temporarily restricted. Russian debtors may fulfill their payment obligation by paying the amount due to a special account in the name of a foreign creditor or a foreign nominee holder of securities, in roubles. Reportedly, the funds cannot be exchanged or transferred outside Russia.

Import and export restrictions

On March 10, the Russian government announced that it had approved a list of imported goods and equipment that are temporarily prohibited from being exported from Russia. The list includes over 200 products, including technological, telecommunication and medical equipment, vehicles, agricultural machinery, electric equipment, as well as railway cars and locomotives, containers, turbines, metal and stone cutting machines, video displays, projectors, consoles and switchboards.

Naturalisation of property

A legislative proposal has been made to the effect that Russian companies controlled (25% or more ownership) by foreign entities in unfriendly states having a balance sheet of more than 1 billion roubles or more than 100 employees that withdraw/suspend their activities in Russia, and this results in that the company is deemed to be unable to perform its obligations or exercise its activities in substantially the same way that it did before, could be placed under forced external management. According to the proposal, the owners of the company will only be able to refuse external administration if either business resumes in Russia, or if the shares are sold under terms that business is upheld and employees maintained. If the owner does not agree to either of these conditions, the company will be put under external administration for three months, after which the company's shares will be put on the market. The potential buyer must agree to keep no less than 2/3 of the working stock and continue the business activities of the old company for at least one year.