Sanctions update 16 March 2022

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

Sanctions newsletter update 11 of MarchSanctions newsletter of 3 of MarchSanctions newsletter of 25 of February EU, US and UK have imposed additional sanctions as follows:


European Union

A forth sanctions package has been decided:

  • The addition of 15 individuals (four oligarchs including Roman Abramovich and other high ranking individuals) to the asset freeze list. The list now comprises of 877 individuals and 62 entities
  • The addition of nine state-owned enterprises to the asset freeze list
  • Prohibition to import/transport a wide variety of Russian steel and iron products including a prohibition to provide ancillary services (financing, technical assistance etc.).
  • Prohibition to invest in the Russian energy sector
  • Prohibition to sell/export certain listed luxury goods in excess of EUR 300 to Russia. The term “luxury goods” is somewhat misleading in that the list (Annex XVIII in Regulation 2022/428) comprises of numerous ordinary goods but instead the value is the decisive factor.
  • Prohibition against transactions with certain listed Russian state-owned companies including Rosneft, Gazprom and Sovcomflot, including companies owned or controlled by them. Notably, the prohibition has two exceptions:

    - transactions which are strictly necessary for the purchase, import or transport of fossil fuels, in particular coal, oil and natural gas, as well as titanium, aluminium, copper, nickel, palladium and iron ore from or through Russia into the EU

    - transactions related to energy projects outside Russia in which a legal person, entity or body listed in Annex XIX is a minority shareholder

  • Prohibition against credit rating services, as well as access to any subscription services in relation to credit rating activities, to any Russian person or entity,
  • An expansion of the list of persons connected to Russia’s defence and industrial base, on whom tighter export restrictions are imposed regarding dual-use goods and goods and technology which might contribute to Russia’s technological enhancement of its defence and security sector

United Kingdom

  • A total of 745 individuals as well as 14 entities have been added to the asset freeze list (on 11 and 15 March respectively)

United States

  • Restrictions on the export, reexport, and transfer of luxury goods to all end users in Russia and Belarus and to certain Russian and Belarusian oligarchs and malign actors located worldwide
  • Restrictions on the importation into the US of fish, seafood, and preparations thereof, alcoholic beverages and non-industrial diamonds.
  • Prohibition against new investment in any sector of the Russian Federation economy as may be determined by the Secretary of the Treasury (no sector yet listed)
  • Prohibition against the exportation from the United States, or by a US person, of US dollar-denominated banknotes to the Russian Government or any person located in Russia

    Given the extremely fast changing sanctions landscape, trade, as well as any business relationship with Russia and entities related to Russia, has become very complex. Companies are recommended to exercise extreme caution, review their operations and seek legal advice as necessary. Sanctions screening should be made against the following lists:

    EU - https://www.sanctionsmap.eu/#/main
    UK - https://sanctionssearch.ofsi.hmtreasury.gov.uk/
    USA - https://sanctionssearch.ofac.treas.gov/