Update: Russian Invasion of Ukraine – Sanctions

Last Updated 12-9-24

December 2024

• Ukraine designated 57 people and 52 entities on its personal special economic and other restrictive measures (sanctions) list. The sanctions apply for 10 years for all those designated.
• The United States sanctioned five individuals and four entities connected to the TGR Group, a sprawling international network that has engaged in sanctions circumvention on behalf of Russian elites.  This action was taken in coordination with the United Kingdom’s National Crime Agency, as well as the U.S. Drug Enforcement Administration and Financial Crimes Enforcement Network.
• Pursuant to Section 212(a)(3)(C), the Department of State announced steps to impose visa restrictions on 17 Russian officials and Russia-appointed proxy authorities for undermining Ukraine’s sovereignty, territorial integrity, or political independence through sham elections held in occupied Ukrainian territories.
• The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned 28 individuals and businesses involved in a global gold smuggling and money laundering network based in Zimbabwe, pursuant to Executive Order (E.O.) 13818, which targets perpetrators of serious human rights abuse and corruption around the world. The global network led by Kamlesh Pattni(Pattni) has facilitated illicit activities by bribing officials, deploying trusted supporters to mask ownership, and weaving a global web of businesses to hide the illicit activities. This fraudulent scheme has robbed Zimbabwe’s citizens of the benefit of those natural resources while enriching corrupt government officials and criminal actors.

November 2024

• The Panama Maritime Authority (AMP) has initiated the process of expedited cancellation of six Panamanian vessels included in the United Kingdom (UK) Sanctions List – Consolidated List of Financial Sanctions Targets in the UK. These actions are supported by the provisions of Executive Decree 512, dated October 18, 2024. This legal mechanism allows the AMP to expeditiously cancel the registration and navigation patent for international or domestic service of vessels of the national merchant fleet that are included in the sanction lists. Additionally, any other document required for navigation that has been issued by the AMP will also be disabled. The six ships were added to the UK list on 25 November, and the Directorate General of the Merchant Marine has therefore recommended that they be cancelled ex officio. Since the publication of Executive Decree 512 of October 18, 2024, Panama has cancelled 3 ships and maintains 8 in the process of cancellation.
• European Union – Parliament condemned Russia’s use of North Korean troops against the Ukrainian army and its testing of new ballistic missiles in Ukraine. These recent escalatory steps represent a new phase in the war and a new risk for Europe’s security as a whole, MEPs argue, calling on the EU and Ukraine’s other partners to respond accordingly. The European Parliament has passed a resolution denouncing Iran, Belarus, and North Korea for their military support of Russia. The resolution urges EU Member States to strengthen the sanctions regimes against these countries.
• United Kingdom announced a wave of new sanctions against Russia’s military industrial complex and Russian-backed mercenary groups. The new targets include suppliers supporting Russia’s military production, Russian-backed mercenary groups operating in Sub-Saharan Africa and a GRU agent involved in the use of a Novichok nerve agent in Salisbury. This package also targets 3 private mercenary groups with links to the Kremlin, including Africa Corps, and 11 individuals associated with Russian proxies. These targets have direct links to the Kremlin, have threatened peace and security in Libya, Mali and the Central African Republic, and have committed widespread human rights abuses across the continent. The 56 designations were made under the Russia (Sanctions) (EU Exit) Regulations 2019, the Central African Republic (Sanctions) (EU Exit) Regulations 2019, the Libya (Sanctions) (EU Exit) Regulations 2020, the Mali (Sanctions) (EU Exit) Regulations 2020 and the Chemical Weapons (Sanctions) (EU Exit) Regulations 2019.
• The Ukraine designated 15 individuals and 39 entities under its personal special economic and other restrictive measures (sanctions) regime.
• United Kingdom – Removed Didier Casimiro, former VP of Rosneft, and made 3 administrative amendments under the Russia sanctions regime.
• United Kingdom – Added 1 new designation under the Russia sanctions regime.

October 2024

• United States – Building on the unprecedented measures already imposed in coordination with allies and partners, the United States imposed sanctions on nearly 400 entities and individuals for enabling Russia’s illegal war against Ukraine. This action targets multiple sectors essential to Russia’s war effort. The Department of State targeted sanctions circumvention by parties in multiple third countries, several senior Russian Ministry of Defense officials and defense companies, and those that support the development of Russia’s future energy production and exports. The DOS imposed sanctions on several PRC-based companies exporting dual-use goods that fill critical gaps in Russia’s military-industrial base as well as entities and individuals connected to the Lukashenka regime’s support for Russia’s defense industry. The Department of the Treasury also targeted third-country sanctions evasion networks that support Russia’s war machine, as well as domestic Russian importers and producers of key inputs for the country’s military-industrial base. Finally, the Department of Commerce added 40 entities to its Entity List and expanded controls on nearly 50 additional entities to combat diversion of sensitive items to Russia. Commerce also restricted exports of additional precursor chemicals to Russia and Belarus to combat Russia’s use of riot control agents and other chemicals on the battlefield in Ukraine.
• United States – Deleted the following two individuals from OFAC’s SDN List:
  • SEMENOVA, Olena Yurevna (a.k.a. SEMENOVA, Elena Iurevna); DOB 06 Dec 1978; citizen Ukraine; Secondary sanctions risk: Ukraine-/Russia-Related Sanctions Regulations, 31 CFR 589.201 and/or 589.209; Passport ER747251 (Ukraine); National ID No. 2882908207 (Ukraine) (individual) [UKRAINE-EO13661].
  • SEMENOVA, Elena Iurevna (a.k.a. SEMENOVA, Olena Yurevna); DOB 06 Dec 1978; citizen Ukraine; Secondary sanctions risk: Ukraine-/Russia-Related Sanctions Regulations, 31 CFR 589.201 and/or 589.209; Passport ER747251 (Ukraine); National ID No. 2882908207 (Ukraine) (individual) [UKRAINE-EO13661].
• United Kingdom – The Foreign, Commonwealth and Development Office sanctioned 3 Russian agencies and 3 senior figures who are attempting to undermine and destabilise Ukraine and its democracy. These firms and their leadership are responsible for a vast malign online network, also commonly known as Doppelganger, which plagues social media with fake posts, counterfeit documents and deepfake material. These deceitful tactics are designed to mask the truth around Russia’s illegal invasion of Ukraine and distract from the true nature of the war. Their murky actions are part of a co-ordinated attempt to use deceptive information operations to undermine democracy in pursuit of their aims.
• Two Russian Nationals Charged For Their Participation In An Illicit Procurement Network That Exported To Russia Sensitive U.S.-Sourced Microelectronics With Military Applications In Violation Of U.S. Export Controls.
• Switzerland – The Federal Council decided to adopt most of the measures in the EU’s 14th package of sanctions against Russia. The new measures came into force on 17 October. On 8 July, 116 individuals and entities were already added to Switzerland’s sanctions list, and on 21 August the first measures in the 14th sanctions package were adopted.
• The United States imposed sanctions on three entities and one individual involved in the development and production of Russia’s Garpiya series long-range attack unmanned aerial vehicle (UAV), which has been deployed in Russia’s brutal war against Ukraine.  The Garpiya, designed and produced in the People’s Republic of China (PRC) in collaboration with Russian defense firms, has been used to destroy critical infrastructure and has resulted in mass casualties. These sanctions targets were involved in the development and production of military equipment for a U.S.-sanctioned Russian defense firm for use by the Russian military in Ukraine.  While the United States previously imposed sanctions on PRC entities providing critical inputs to Russia’s military-industrial base, these are the first U.S. sanctions imposed on PRC entities directly developing and producing complete weapons systems in partnership with Russian firms.
• The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) added 26 entities to the Entity List for activities contrary to U.S. national security and foreign policy under the destinations of the People’s Republic of China (PRC) (6), Egypt (1), Pakistan (16), and the United Arab Emirates (UAE) (3). These additions are related to alleged violations of export controls, involvement in weapons programs of concern, and evasion of U.S. sanctions and export controls on Russia and Iran.
• The United States took additional action against affiliates of the Russia-based, U.S.-designated cybercrime group Evil Corp.  The Department of the Treasury is designating seven individuals, and two entities associated with the group. Additionally, the Department of Justice unsealed an indictment charging one of the Evil Corp members for his use of BitPaymer ransomware targeting victims in the United States. Evil Corp is a Russia-based cybercriminal organization responsible for the development and distribution of the Dridex malware. Evil Corp has used the Dridex malware to infect computers and harvest login credentials from hundreds of banks and other financial institutions in over 40 countries, resulting in more than $100 million in theft losses and damage suffered by U.S. and international financial institutions and their customers.
• The United Kingdom sanctioned 16 members of prolific Russian cyber-crime gang Evil Corp. Known for their Mafia style of operation; Evil Corp has waged a campaign of destructive cyber-attacks worldwide for over a decade. Alongside the sanctions action, the NCA, FBI and Australian Federal Police have released a public document revealing Evil Corp’s ties to the Russian state and their history of trying to adapt to a changing cyber landscape to cause as much harm as possible, including by pioneering new forms of cyber-crime.
• Australia imposed targeted financial sanctions, and travel bans on three Russian citizens for their involvement in the Evil Corp cybercrime group. This is the third use of Australia’s autonomous cyber sanctions framework, and part of ongoing coordinated international law enforcement against cybercrime.
• United Kingdom – The Foreign, Commonwealth and Development Office updated the UK Sanctions List. The following entries have been added to the Chemical Weapons financial sanctions regime and are now subject to an asset freeze: Igor Anatolyevich Kirillov, 33rd Central Scientific Research and Testing Institute, Radiological Chemical and Biological Defence Troops of the Ministry of Defence of the Russian Federation, Russian Ministry of Defence 27th Scientific Centre.
• Ukraine designated 90 individuals and 4 entities under its personal special economic and other restrictive measures (sanctions) regime.
• European Union – Adopted new sanctions regime in response to hybrid threats from Russia. The Council established a new framework for restrictive measures in response to Russia’s destabilising actions abroad. This new framework will enable the EU to address a variety of hybrid threats, such as: the undermining electoral processes and the functioning of democratic institutions; threats against and sabotage of economic activities, services of public interest or critical infrastructure; the use of coordinated disinformation, foreign information manipulation and interference (FIMI); malicious cyber activities, the instrumentalisation of migrants, and other destabilizing activities. Under this newly established framework, those designated will be subject to an asset freeze and EU citizens and companies will be forbidden from making funds available to them. In addition, natural persons will also be subject to a travel ban, which will prevent them from entering or transiting through EU territories.
• United Kingdom – The Foreign, Commonwealth and Development Office updated the UK Sanctions List. Two entries were amended under the Russia Financial Sanctions Regime.

September 2024

• The Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Russia-related General License 13K, “Authorizing Certain Administrative Transactions Prohibited by Directive 4 under Executive Order 14024.” There were also Russia-related Designation Removals from the SDN List and Russia-/Ukraine-related Identification Updates.
• The United States designated five entities and one individual involved in illicit payment mechanisms between Russia and the DPRK.  This action exposes and disrupts networks that facilitate the funding of the DPRK’s unlawful weapons of mass destruction and ballistic missile programs and that support Russia’s illegal war against Ukraine.
• Ukraine designated 6 individuals and over 40 entities from Russia, Iran and China in Presidential Decrees No. 638 and No. 639.
• New Zealand – Designated five individuals and six entities, including Belarusian individuals and entities providing material support to the Russian invasion and A Russian entity involved in Russia’s illegal occupation and control of Ukraine’s Zaporizhzhya Nuclear Power Plant.
• Switzerland – The Federal Department of Economic Affairs EAER amended annex 8 to the ordinance on measures connected with the situation in Ukraine (RS 946.231.176.72). The entries concerning 6 individuals have been modified and the entries concerning 8 individuals have been deleted.
• The Department of State announced reward offers under the Transnational Organized Crime Rewards Program of up to $10 million each for information leading to the arrests and/or convictions of Timur Shakhmametov and Sergey Ivanov for participating in, conspiring to participate in, and attempting to participate in transnational organized crime.  Separate reward offers of up to $1 million each are also being offered for information leading to the identification of other leaders of the Joker’s Stash criminal marketplace (other than Shakhmametov), as well as the identification of other key leaders of the UAPS, PM2BTC, and PinPays transnational criminal groups (other than Ivanov). Concurrently, the Department of the Treasury sanctioned Ivanov and Russia-operating virtual currency exchange Cryptex, and issuing an order that identifies PM2BTC as being of “primary money laundering concern” in connection with Russian illicit finance.  These actions are part of a coordinated international effort to disrupt Russian cybercrime services and are being taken in conjunction with actions by other U.S. government agencies and international law enforcement partners. According to the U.S. Secret Service (USSS), Shakhmametov allegedly utilized the moniker “JokerStash” in his capacity as the creator/operator of Joker’s Stash, one of the most profitable online marketplaces for stolen credit card data and compromised personally identifiable information. Ivanov laundered the proceeds from Joker’s Stash.  USSS alleges Ivanov to be a reliable, long-term provider of money laundering services for top tier cybercriminals since approximately 2005.
• The UK sanctioned 5 ships, and 2 entities involved in the Russian Liquified Natural Gas (LNG) sector. This is the first time the UK is using its new ship specification power to target LNG vessels directly. The UK has now sanctioned 15 vessels and entities involved in the Russian LNG sector and we will continue to bear down on this important source of funding for Putin’s illegal war in Ukraine.
• The US Bureau of Industry and Security  issued11 export control orders. The order deny export privileges of certain individuals who have been convicted under  18 U.S. Code § 371 or 18 U.S. Code § 554. Those convicted under these sections can have export privileges denied for up to 10 years from the date of their conviction.
• The Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated 4 individuals, 3 entities and 9 vessels to the SDN List under Executive Order 14024 [RUSSIA-EO14024].
• The Department of State took action today to constrain further Iran’s destabilizing activities, including its transfer of ballistic missiles to Russia, a serious escalation in its support for Russia’s illegal war against Ukraine.  The expanding military partnership between Iran and Russia threatens European security and illustrates how Iran’s destabilizing influence reaches beyond the Middle East to undermine security around the world.
• The UK has sanctioned 10 vessels in Russia’s ‘shadow fleet’, a group of ships that use illicit practices to avoid sanctions on Russian oil.
• UK government announced significant measures against Iran and Russia, following the Iranian regime’s transfer of ballistic missiles to Russia.
• the United States designated three entities and two individuals for allegedly attempting to interfere in the Moldovan elections and their connection to Russia’s destabilizing actions abroad. According to new information, much of which originates from employees of Russian state-funded RT (formerly “Russia Today”), we now know that RT moved beyond being simply a media outlet and has been an entity with cyber capabilities. It is also engaged in information operations, covert influence, and military procurement. These operations are targeting countries around the world, including in Europe, Africa, and North and South America.
• The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated10 individuals and two entities as part of a coordinated U.S. government response to Moscow’s malign influence efforts targeting the 2024 U.S. presidential election. Russian state-sponsored actors have long used a variety of tools, such as generative artificial intelligence (AI) deep fakes and disinformation, in an attempt to undermine confidence in the United States’ election processes and institutions. Beginning in early 2024, executives at RT—Russia’s state-funded news media outlet—began an even more nefarious effort to covertly recruit unwitting American influencers in support of their malign influence campaign. RT used a front company to disguise its own involvement or the involvement of the Russian government in content meant to influence U.S. audiences.
• The Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Russia-related General License 108, “Authorizing Limited Safety and Environmental Transactions Involving Certain Blocked Persons or Vessels.” In addition, two entities and two vessels were added to OFAC’s SDN List.
• the Department of State is targeting two entities and two vessels connected to attempts to export liquefied natural gas (LNG) from the U.S.-sanctioned Arctic LNG 2 project. The Department sanctioned Gotik Energy Shipping Co (Gotik) and Plio Energy Cargo Shipping OPC PVT LTD (Plio Energy). Gotik and Plio Energy are the registered owner and commercial manager, respectively, of the LNG carrier (LNG/C) New Energy. LNG/C New Energy used deceptive shipping practices, including shutting off its automatic identification system, to load cargo from the U.S.-sanctioned Arctic LNG 2 project via a ship-to-ship transfer on August 25, 2024, with LNG/C Pioneer, a vessel blocked by the United States on August 23, 2024. We are also identifying one additional vessel managed and operated by Plio Energy, LNG/C Mulan, as property in which Plio Energy has an interest. Gotik and Plio Energy are being designated pursuant to Section 1(a)(vi)(B) of E.O. 14024, as amended, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Limited Liability Company Arctic LNG 2, a person whose property and interests in property are blocked pursuant to E.O. 14024. New Energy (IMO 9324277) is being identified as property in which Gotik has an interest, and Mulan (IMO 9864837) is being identified as property in which Plio Energy has an interest.
• The Department of Justice unsealed two indictments charging Dimitri Simes, 76, and Anastasia Simes, 55, both of Huntly, Virginia, and Russia with two separate schemes to violate U.S. sanctions. As alleged in the first indictment, Dimitri and Anastasia Simes participated in a scheme to violate U.S. sanctions for the benefit of sanctioned Russian broadcaster Channel One Russia and to launder funds obtained from that scheme. Channel One Russia, a state-owned Russian television station, was sanctioned by the Treasury Department’s Office of Foreign Assets Control (OFAC) on May 8, 2022, for being owned or controlled by, or for having acted or purported to act for or on behalf of, the Government of the Russian Federation.

August 2024

• The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) deleted Ilya Borisovich BRODSKIY from the SDN List [RUSSIA-EO14024]
• The Justice Department unsealed a criminal complaint charging Hungarian national Bence Horvath with violations of U.S. export controls targeting Russia, including by conspiring with others to illegally export U.S.-origin radio communications technology to Russian government end users without a license. Horvath is charged by complaint with one count of conspiring to violate the Export Control Reform Act of 2018 (ECRA). He was arrested on arrival at San Francisco International Airport in San Francisco, California, on Aug. 23.
• The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) took action against 19 individuals, 14 entities, and one aircraft pursuant to Belarus-related Executive Order (E.O.) 14038. This action targets persons involved in supporting Russia’s war in Ukraine through military resource production and transshipment of goods to Russia, sanctions evasion on behalf of Belarusian defense entities, and revenue generation for Belarusian oligarchs in Alyaksandr Lukashenka’s inner circle. OFAC is concurrently designating five of these targets—three individuals and two entities—pursuant to Russia-related E.O. 14024.
• the United States sanctioned nearly 400 entities and individuals for enabling Russia’s prosecution of its illegal war in Ukraine. With this action, the Department of State is imposing sanctions on more than 190 individuals and entities.  Concurrently, the Department of the Treasury is designating nearly 200 individuals and entities.
• The Commerce Department’s Bureau of Industry and Security (BIS) is taking aggressive action to further restrict the supply of both U.S.-origin and “U.S. branded” (i.e., labeled) items to Russia and Belarus for the Kremlin’s illegal war on Ukraine. The actions will further constrain Russia’s ability to arm its military by targeting illicit procurement networks designed to circumvent global export controls.
• Switzerland – the Federal Council decided to adopt further measures of the EU’s 14th package of sanctions against Russia. These include a clarification of the bans on Russian diamonds, making them internationally harmonized. The Federal Council has also extended the deadlines for granting exemption permits with regard to the withdrawal of investments from Russia. The aim is to ensure that Swiss companies can legally terminate their business activities in Russia. The amendments entered into force on 27 August.

July 2024

• The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) today announced a $7,452,501 settlement with State Street Bank and Trust Company (State Street), a Massachusetts-based financial institution, on behalf of itself and its subsidiary, Charles River Systems, Inc. (Charles River).  State Street agreed to settle its potential civil liability for 38 apparent violations of OFAC’s Ukraine-/Russia-Related sanctions.  The apparent violations involved invoices that were redated or reissued by Charles River between 2016 and 2020 for certain customers who were subject to Directive 1 of Executive Order 13662, as well as certain payments outside of the applicable debt tenor accepted by Charles River from these customers.  The settlement amount reflects OFAC’s determination that the apparent violations were not voluntarily self-disclosed and were egregious.
• The United Kingdom designated 11 tankers and issued joint call to action in Russia’s “shadow fleet”.
• The United States designated Yuliya Vladimirovna Pankratova (Pankratova) and Denis Olegovich Degtyarenko (Degtyarenko), two members of the Russian hacktivist group Cyber Army of Russia Reborn (CARR) for their roles in cyber operations against U.S. critical infrastructure entities. Since 2022, CARR has conducted malicious cyber activities against Ukraine and governments that support Ukraine.  In late 2023, CARR escalated its operations, claiming responsibility for compromising the industrial control systems of multiple U.S. and European critical infrastructure targets.  CARR has since been responsible for a slew of malicious cyber activities against water supply, hydroelectric, wastewater, and energy facilities in the United States and Europe.
• Ukraine designated 3 Russian individuals and 1 UK-based entity, and extended sanctions against 390 individuals and 366 companies linked to Russia for a further 5 or 10 years.
• European Union listed two individuals and four entities for circumventing EU sanctions and materially supporting the Russian government.
• South Korea designated 5 entities, 4 vessels, and 8 individuals from Russia, North Korea, and third countries allegedly involved in the transport of weapons between Russia and North Korea, the import of petroleum to North Korea, and North Korea’s nuclear and missile development.
• United States – OFAC added “secondary sanctions risk” to thousands of Russia sanctions listings.
• United States – OFAC de-listed Alexey Valeryevich PANFEROV and Marina Igorevna TSAREVA from the sanctions list.
• New Zealand announced further sanctions on Iranian actors involved in providing military assistance to Russia, specifically through the production and supply of drones. The new sanction package also includes Russian individuals and entities involved in the illegal transfer of weaponry from North Korea to Russia for use in Ukraine. According to a statement by the New Zealand Foreign Ministry, these sanctions target seven individuals and 12 entities providing military support for Russia’s invasion of Ukraine. The Iranian individuals are Mohsen Vahabzadeh Moghadam, Abbas Abdi Asjerd, and Ehsan Varnosfaderani. The list also includes entities such as Bonyan Danesh Shargh, Alvand Motorbuilding Industries Company, Pishro Sanat Aseman Sharif Company, and Saad Sazeh Faraz Sharif Company.
• European Union – The Council of the EU issued a notice of its intention to maintain restrictive measures against 3 Russian individuals: Oleg Savelyev, Sergey Kuzovlev, and Aleksandr Lapin.
• The European Union extended its existing sanctions against Iran for another year over alleged support for Russia in the Ukraine war as well as support for resistance groups in the West Asia region.

June 2024

• European Union – six persons added to EU sanctions list for malicious cyber activities against EU member states and Ukraine. The cyber-attacks affecting information systems relating to critical infrastructure, critical state functions, the storage or processing of classified information and government emergency response teams in EU member states. The new listings include two members of the ‘Callisto group’, Ruslan Peretyatko and Andrey Korinets. The ‘Callisto group’ is a group of Russian intelligence officers conducting cyber operations against EU member states and third countries through sustained phishing campaigns intended to steal sensitive data in critical state functions, including defence and external relations. The EU also targeted Oleksandr Sklianko and Mykola Chernykh of the ‘Armageddon hacker group’, a group supported by the Federal Security Service (FSB) of the Russian Federation that carried out various cyber-attacks with a significant impact on the governments of EU member states and Ukraine, including by using phishing emails and malware campaigns. In addition, Mikhail Tsarev and Maksim Galochkin, key players in the deployment of the malwares ‘Conti’ and ‘Trickbot’ and involved in ‘Wizard Spider’, are also sanctioned. Trickbot is a malicious spyware program, created and developed by the threat group ‘Wizard Spider’, which has conducted ransomware campaigns in a variety of sectors, including essential services such as health and banking, and is therefore responsible for significant economic damage in the European Union.
• United Kingdom – delisted Aleksei Nikolaevich FILIPPOVSKII
• Japan imposed measures under the Foreign Exchange and Foreign Trade Act regarding the situation in Ukraine. The measures include:
  • Asset freeze and other measures. The measures have been implemented against Russian Federation officials (10 individuals and 27 organizations) designated as targets of asset freezes and other measures in accordance with the Ministry of Foreign Affairs Public Notification, those deemed to be directly involved in the “annexation” of the Autonomous Republic of Crimea and the Special City of Sevastopol to the Russian Union or the destabilization of eastern Ukraine, and those deemed to be directly involved in the act referred to as “incorporation” by the Russian Federation in the eastern and southern regions of Ukraine (1 individual and 1 organization), as well as those deemed to be related to countries other than the Russian Federation and the Republic of Belarus (1 organization).
  • Prohibition measures concerning exports, etc. to certain entities in the Russian Federation and to certain entities in countries other than the Russian Federation and the Republic of Belarus. Prohibition measures will be implemented regarding exports, etc. to 14 organizations designated as specific organizations in the Russian Federation by the Ministry of Foreign Affairs, as well as 10 organizations designated as specific organizations in countries other than the Russian Federation and the Republic of Belarus.
• European Union Court annulled Russia listings of Dmitry Pumpyanskaya and Galina Evgenyevna Pumpyanskaya.
• United States – The Bureau of Industry and Security added four entities in China and one entity in Russia, as well as eight addresses in China, to the Entity List in Supplement No. 4 to Part 744 of the Export Administration Regulations (EAR).
• United States – The Department of Commerce’s Bureau of Industry and Security Imposed $285,000 Penalty Against Sapphire Havacilik San Ltd. STI to Resolve Alleged Violations of Unlicensed Reexports to Russia

• Russia banned news organizations from 25 EU member states, as well as Europe-wide media such as EUobserver and Politico. The Kremlin accused them of “systematically distributing inaccurate information” about what Russia calls its “special military operation” in Ukraine.
• European Union – six persons added to EU sanctions list for malicious cyber activities against EU member states and Ukraine. The cyber-attacks affecting information systems relating to critical infrastructure, critical state functions, the storage or processing of classified information and government emergency response teams in EU member states. The new listings include two members of the ‘Callisto group’, Ruslan Peretyatko and Andrey Korinets. The ‘Callisto group’ is a group of Russian intelligence officers conducting cyber operations against EU member states and third countries through sustained phishing campaigns intended to steal sensitive data in critical state functions, including defence and external relations. The EU also targeted Oleksandr Sklianko and Mykola Chernykh of the ‘Armageddon hacker group’, a group supported by the Federal Security Service (FSB) of the Russian Federation that carried out various cyber-attacks with a significant impact on the governments of EU member states and Ukraine, including by using phishing emails and malware campaigns. In addition, Mikhail Tsarev and Maksim Galochkin, key players in the deployment of the malwares ‘Conti’ and ‘Trickbot’ and involved in ‘Wizard Spider’, are also sanctioned. Trickbot is a malicious spyware program, created and developed by the threat group ‘Wizard Spider’, which has conducted ransomware campaigns in a variety of sectors, including essential services such as health and banking, and is therefore responsible for significant economic damage in the European Union.
• EU adopts 14th package of sanctions against Putin’s regime. The new sanctions target high-value sectors of the Russian economy such as energy, finance and trade, and make it increasingly difficult to circumvent EU sanctions. They include:
  • a ban on reloading services for Russian liquified natural gas (LNG) on EU territory for the purpose of transshipment operations to third countries
  • a ban on new investments for the completion of LNG projects under construction
  • outlawing the use of the ‘System for Transfer of Financial Messages’ (SPFS)
  • a ban on port access and the provision of services to vessels contributing to Russia’s war
  • a wider EU flight ban
  • further import-export controls and restrictions
  • In addition, political parties and foundations, and NGOs will no longer be allowed to accept funding from Russia, and 116 entities and individuals have been sanctioned.
• Canada announced additional sanctions against Russia and its illegal war against Ukraine. These sanctions target many individuals and entities implicated in disinformation and propaganda operations, including those identified by Rapid Response Mechanism Canada. They also include entities in Russia’s military-industrial complex that supply key technology and electrical components in support of Russia’s war efforts. In addition, the sanctions target entities involved in sanctions circumvention that facilitate Russia’s access to sanctioned goods or to revenue from oil sold above the G7 price cap.
• UK announced 50 new sanctions designations and specifications to degrade Putin’s war machine, in coordinated action with G7 partners to support Ukraine
• US expanded sanctions on Russia. U.S. Department of the Treasury issued sweeping new measures guided by G7 commitments to intensify the pressure on Russia for its continued cruel and unprovoked war against Ukraine. The actions ratchet up the risk of secondary sanctions for foreign financial institutions that deal with Russia’s war economy; restrict the ability of Russian military-industrial base to take advantage of certain U.S. software and information technology (IT) services; and, together with the Department of State, target more than 300 individuals and entities both in Russia and outside its borders—including in Asia, the Middle East, Europe, Africa, Central Asia, and the Caribbean—whose products and services enable Russia to sustain its war effort and evade sanctions.
• Russia – The Ministry of Foreign Affairs published retaliatory measures in connection with the revocation of accreditations of Russian journalists in Austria. Measures were taken against the journalist of the Moscow bureau of the Austrian Radio and Television (“ORF”) M. Knieps-Witting. On June 10, she was ordered to hand over her accreditation certificates and leave the territory of the Russian Federation in the near future.
• Russia announces fresh sanctions against multiple UK figures
  Russia’s foreign ministry has added a number of British “establishment figures”, journalists and experts to its list of people banned from entering Russia, it has announced, saying it was doing so over their “hostile” actions.
• The Department of the Treasury’s Office of Foreign Assets Control (OFAC) continues to counter Russia’s destabilizing activities in Africa by sanctioning two companies that are linked to the Private Military Company “Wagner” (Wagner Group). Mining Industries SARLU and Logistique Economique Etrangere SARLU are being designated pursuant to Executive Order (E.O.) 14024 for enabling Wagner Group security operations and Wagner Group-linked illicit mining endeavors in the Central African Republic (CAR).

May 2024

• US Department of Treasury and the Department of State Imposed sanctions on nearly 300 entities and individuals, including those engaged in the development of Russia’s future energy, metals and mining production and export capacity. The new measures also target Russia’s military-industrial base and chemical and biological weapons programs as well as companies and individuals in third countries that purportedly help Russia acquire components for weapons or defense-related production.
• US Department of Treasury, OFAC Removes the former Swiss unit of Sberbank of Russia, Sberbank (Switzerland) AG, from its sanctions list following the bank’s sale, restructuring and rebranding to TradeXBank AG.
• The US Department of the Treasury’s Office of Foreign Assets Control designates Russian individual Dmitrii Aleksandrovich Beloglazov and companies Obshchestvo S Ogranichennoi Otvetstvennostiu Titul, Aktsionernoe Obshchestvo Iliadis and International Co. Joint Stock Co. Rasperia Trading Ltd. as being involved in a scheme that would have enabled sanctioned Russian billionaire Oleg Deripaska to sell shares worth $1.5 billion in an unnamed European company.
• The EU Council broadens its restrictive measures against Iran, targeting individuals and entities supplying, selling or involved in the transfer of Iran’s missiles and unmanned aerial vehicles in support of Russia’s war in Ukraine and armed groups in the Middle East and Red Sea region.
• The EU decided to suspend the broadcasting activities of four additional Russian-associated media outlets, in view of their role in supporting Russia’s war of aggression against Ukraine and destabilising its neighbouring countries. Voice of Europe, RIA Novosti, Izvestia and Rossiyskaya Gazeta.
• Japan imposes sanctions on nine Russian entities and one Russian individual, well as two Cyprus-based companies over Russia’s weapons procurements from North Korea.
• South Korea imposes sanctions on two Russian vessels transporting military supplies between Russia and North Korea; and on seven North Korean individuals regarding various activities involving assistance for Russia from North Korea.
• The EU Council sanctioned two individuals and one entity responsible for information manipulation in Russia’s war of aggression against Ukraine.
• The EU Council established a new sanctions regime against those responsible for serious human rights violations or abuses, repression of civil society and democratic opposition, and undermining democracy and the rule of law in Russia, and listed 19 people and one entity.
• Russia, President Vladimir Putin has signed a decree allowing Russia to confiscate assets of U.S. companies and individuals to compensate for any Russian assets confiscated in the United States.
• Canada imposed additional sanctions on two individuals and six entities under the Special Economic Measures (Russia) Regulations. These sanctions target individuals and entities that facilitated the illegal transportation of weapons, including ballistic missiles, from North Korea to Russia. There is recorded evidence that these weapons were used by the Kremlin to conduct its war of aggression against Ukraine in 2023 and 2024.
• The UK introduced new Regulations to expand the criteria for the people and entities who can be designated under the UK Russian sanctions regime, as set out in Regulation 6 of the Russian (Sanctions) Regulations 2019. The new criteria permits the designation of people or entities for:

• • Providing financial services, or making available funds, economic resources, goods or technology to persons involved in obtaining a benefit from or supporting the Government of Russia; and
  • Owning or controlling directly or indirectly, or working as a director, trustee, other manager or equivalent of a person, other than an individual, involved in destabilizing Ukraine or undermining or threatening the territorial integrity, sovereignty or independence of Ukraine.
  • The new Regulations also expand the criteria regarding the ships which the Secretary of State may “specify”. The amendments to regulation 57F (specification of ships) provide that a ship may be specified for any activity whose object or effect is to destabilize Ukraine or undermine or threaten the territorial integrity, sovereignty, or independence of Ukraine, or to obtain a benefit from or support the Government of Russia.

April 2024

• US Department of the Treasury Sanctions Lukashenka Regime Based on a Determination of Sanctions Evasion. The US Department of the Treasury designated 12 entities and 10 individuals based on a determination that the Belarusian Lukashenka regime continued to rely on revenue from state-owned enterprises to suppress its citizens, to circumvent US sanctions, and to support Russia’s war against Ukraine.
• Russia Bans Entry to 247 Citizens of Baltic States in Response to Sanctions. The Ministry of Foreign Affairs of the Russian Federation published a press release on banning representatives of certain Baltic states “hostile to [Russia]” entry to the Russian Federation. These states include Latvia, Lithuania and Estonia, and the individuals added to Russia’s “stop list” include ministers, parliament members, public figures and journalists.
• Ukraine Updates Sanctions List. Ukraine updated its sanction lists adding 7 individuals and 86 legal entities. The relevant decision was adopted by the Order of the President of Ukraine No. 219/2024 dated 4 April 2024.
• The Russian Foreign Ministry Imposed Sanctions against Australian Members of Parliament: Russia has banned the entry of 235 members of municipal assemblies of Victoria and South Australia into the Russian territory. The move was taken in retaliation against Australian sanctions.

March 2024

• US Department of the Treasury Sanctions Russian Companies Based on a Determination that They Were Supporting Sanctions Evasion. The US Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned thirteen entities and two individuals based on a determination that they were operating in the financial services and technology sectors of the Russian Federation economy, including persons developing or offering services in virtual assets, that enable the evasion of US sanctions. Five entities were also designated for being owned or controlled by OFAC-designated persons.

• US Department of the Treasury Sanctions Companies Based on a Determination that They Were Advancing Russian Malign Activities in Africa. OFAC sanctioned two companies – one in Russia, Limited Liability Company Broker Export, and one in the Central African Republic (CAR), Bois Rouge SARLU – based on a determination that they were advancing Russia’s malign activities, including seeking monetary gain from illicit natural resource extraction and providing material and financial support to the Wagner Group and other organizations associated with the enterprise of Yevgeniy Prigozhin, in the CAR.
• EU Sanctions 33 Individuals and Two Entities. The EU imposed restrictive measures against 33 persons and two entities linked to the sudden death in a penal colony of the Russian opposition politician Alexei Navalny. This decision was taken in the framework of the European Union’s Global Human Rights Sanctions Regime.
• EU Individual Sanctions over Territorial Integrity Prolonged for a Further Six Months. The EU decided to prolong sanctions measures targeting those responsible for undermining or threatening the territorial integrity, sovereignty and independence of Ukraine for another six months, until 15 September 2024.
• EU Sanctions in View of the Situation in Ukraine Prolonged for a Further Six Months. The EU decided to prolong sanctions measures imposed against certain persons, entities and bodies in view of the situation in Ukraine, until 6 March 2025. The EU also updated the framework with regard to the rights of defense and the right to effective judicial protection.
• UK Government Revokes One Entry on the UK Sanctions List under the Russia Regime. The UK Government revoked Igor Viktorovich Makarov entry on the UK sanctions list. Mr. Makarov is no longer subject to an asset freeze, travel ban, transport sanctions, or trust services sanctions.
• UK Government Amends One Entry on the UK Sanctions List under the Russia regime. The UK Government made a correction to the entry for Vladimir Vladimirovich Mikheychik under the Russia sanctions regime. This individual remains subject to an asset freeze and trust services sanctions.
• Ukraine Abolishes the Register of the “International Sponsors of War”: The National Agency of Ukraine for the Prevention of Corruption has announced that it will no longer maintain its register of “International sponsors of war”. The register included large multinationals which continued business in Russia after the start of the war. The listing had no legal consequences and was used for “shaming” purposes, however, operation of the register caused controversies between Ukraine and foreign partners.
• Canada Imposes Additional Sanctions against Russia. Canada imposed sanctions on six Russian officials, including senior officials and high-ranking employees of Russia’s prosecution, judicial, and correctional services over the death of opposition leader, Alexei Navalny.
• Australia Issues Additional Sanctions Following Alexei Navalny’s Death in Prison. The Australian Government imposed additional targeted financial sanctions and travel bans on three Russian officials linked to the prison where Alexei Navalny died.

February 2024

• US Department of the Treasury Sanctions Almost 300 Individuals and Entities. The US Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned almost 300 individuals and entities, including targets in Russia’s financial infrastructure and military-industrial base and more than two dozen third-country sanctions evaders in Europe, East Asia, Central Asia, and the Middle East. As part of OFAC’s targeting of Russia’s core financial infrastructure, OFAC’s sanctions included the National Payment Card System Joint Stock Company (NSPK), which is the state-owned operator of Russia’s Mir National Payment System. NSPK is owned by the Central Bank of Russia and plays a key role in facilitating financial transactions both internal to Russia and abroad.
• US Department of the Treasury Designates Russian State-Owned Sovcomflot, Russia’s Largest Shipping Company. The US through OFAC, as part of an international coalition of countries, the Price Cap Coalition; including the G7, the EU, and Australia, that have agreed to prohibit the import of crude oil and petroleum products of Russian Federation origin; designated the Joint Stock Company Sovcomflot (Sovcomflot), Russia’s state-owned shipping company and fleet operator. In addition to designating Sovcomflot, OFAC identified 14 crude oil tankers as property in which Sovcomflot has an interest.
• US Department of the Treasury Sanctions Affiliates of Russia-based LockBit Ransomware Group. OFAC designated two individuals who are affiliates of the Russia-based ransomware group, LockBit. This action was the first in ongoing US collaborative efforts with the US Department of Justice, Federal Bureau of Investigation, and international partners to target LockBit.
• US Department of the Treasury Targets Price Cap Violation Network and Implements G7 Ban on Russian Diamonds. OFAC took its second price cap enforcement of 2024 by imposing sanctions on four entities and identifying one vessel as blocked property. OFAC also issued two new determinations that implement G7 commitments to ban the importation of Russian diamonds.
• US Department of State Imposes Sanctions on more than 250 Entities and Individuals. The Department of State imposed more than 250 sanctions on entities and individuals, including those engaged in sanctions evasion and circumvention, and those bolstering Russia’s future energy and metals and mining production. These sanctions also included several individuals for acts supporting Russia’s war, including the unlawful transfer and/or deportation of Ukrainian children. The Department of State also announced that it is taking steps to impose visa restrictions on Russia Federation-installed purported authorities involved in human rights abuses in connection with the transfer, deportation, and confinement of Ukrainian children.
• US Department of Commerce Adds 93 Entities in Russia to Its Entity List. The Department of Commerce Bureau of Industry and Security (BIS) imposed additional export restrictions on 93 entities in Russia and seven other destinations for a variety of reasons related to their activities in support of Russia’s defense-industrial sector and war effort. More than 50 of the entities added to the list will also receive a “footnote 3” designation as Russian-Belarusian military end users. A footnote 3 designation subjects the entities to some of the most severe restrictions under the Export Administration Regulations (EAR). The entities are added with a license requirement for all items subject to the EAR and a license review policy of denial, apart from food and medicine designated as EAR99, which will be reviewed on a case-by-case basis by BIS.
• US Department of State Announces Reward Offer for Information Leading to the Arrest and/or Conviction of a Russian Sanctions Evader. The Department of State announced a reward offer under the Transnational Organized Crime Rewards Program of up to $1 million for dual Russian-Swiss national, Vladislav Osipov, for information leading to his arrest and/or conviction for participating in, conspiring to participate in, or attempting to participate in transnational organized crime.
• US – Russian Canadian National Pleads Guilty to Conspiracy to Launder Money from Scheme to Send UAV and Missile Components to Russia. The Department of Justice released that Kristina Puzyreva, a Russia-Canadian National, pleaded guilty to money laundering conspiracy for her role in a multimillion-dollar scheme to send components used in unnamed aerial vehicles (UAVs) and guided missile systems and other weapons to sanctioned entities in Russia.
• EU Adopted 13th Sanctions Package against Russia. The EU adopted its 13th sanctions package against Russia. The new package introduces additional asset freeze measures. It also amends sectoral sanctions targeting Russia by extending the list of entities subject to enhanced export control restrictions on dual-use and advanced technology items, further limiting Russia’s access to electronic components and facilitating trade in iron and steel products between the EU and the UK.
• EU Extends Sanctions in Response to the Illegal Recognition, Occupation or Annexation by Russia of Certain Areas of Ukraine for a Year. The EU renewed sanctions imposed in response to the illegal annexation of Ukraine’s Donetsk, Kherson, Luhansk and Zaporizhzhia regions by Russia for a further 12 months, until 24 February 2025.
• European Commission Comments on Allegations Concerning Sanctions Evasion through Third Countries. The Finnish manufacturer and supplier of air traffic control equipment, NRPL Aero, has disclosed that Finland sold 2.5 tons of radar equipment valued at EUR 1.3 million to the Kazakh supplier of software and hardware for radio navigation equipment, AG TECH LLP, on behalf of the Kazakh air navigation services provider, Kazaeronavigatsia. The equipment was delivered to Shymkent International Airport, but allegedly there is reason to believe that this radar equipment might be delivered to Russia rather than Shymkent. In reaction to these allegations, the European Commission reaffirmed that it engages in a regular dialogue with third country authorities, including Kazakhstan, where a risk of circumvention has been identified, with particular attention to critical items for Russia’s military, industrial and economic development. Regarding the allegation of the loophole of derogations, the Commission explained that it is for the national competent authorities to assess applications for derogations from the sanctions in force, within the framework set by European and national law.
• European Commission Comments on Sanctions on Russian LNG and Natural Gas Imports: Fluxys, the Belgium-based natural gas transmission operator, owning a gas terminal in Zeebrugge, which is one of the major transit hubs for Russian liquefied natural gas (LNG) claims that it cannot unilaterally stop imports from Russia, owing to breach of contract, juridical consequences and fines. It thus asked the European Commission whether it plans to propose sanctions to the Council on Russian LNG/gas imports or envisages alternative measures to sanctions packages that can enable Fluxys to end its contract with Yamal, while avoiding lawsuits and fines. In its response, the European Commission explained that although some Member States have already voluntarily stopped importing LNG of Russian origin, there are no EU restrictions on the import of natural gas from Russia either via pipeline or as LNG. However, the Commission has repeatedly urged Member States to reflect on the appropriateness of imports of LNG from Russia. The European Commission further emphasized that the politically agreed Hydrogen and Decarbonized Gas Market Package will also allow Member States to adopt restrictions to the supply of natural gas, including LNG, from Russia or Belarus, with the aim of protecting the essential security interests of the Member states or of the EU.
• European Commission Comments on Allegations against PwC and Others. The European Commission explained in light of the allegations against PwC and others, the Commission contacted the authorities in Cyprus and welcomed the public comments by President of Cyprus, N. Christodoulides on the invitation extended to financial crime experts to help Cyprus with its ongoing investigations. The Commission continues to stand ready to support Cyprus in this important work.
• UK Government Amends One Entry on the UK Sanctions List under the Russia Regime. The UK Government made one administrative amendment to the entry for Ilya Borisovich Brodskiy under the Russia sanctions regime. This individual remains subject to an asset freeze, travel ban, trust services sanctions, and transport sanctions.
• UK Government Amends One Entry on the UK Sanctions List under the Russia Regime. The UK Government amended the entry for Ilya Borisovich Brodskiy under the Russia sanctions regime. This individual remains subject to an asset freeze and trust services sanctions, and is not subject to transport sanctions.
• UK Government Adds More Than 50 Entries to the UK Sanctions List under the Russia and Belarus Regimes. The UK Government designated more than 50 individuals and businesses in connection with Russia’s invasion of Ukraine. These sanctions target key sources of Russian revenue such as metals, diamonds, and energy trade, as well as parties that Russia with munitions. The new targets include munitions manufacturers, electronics companies, diamond and oil traders, and oil and gas companies (such as Arctic LNG 2, one if its directors and six directors of PJSC Novatek, majority owner of Arctic LNG 2).
• UK Government Adds Six Entries to the Sanctions List under the Human Rights Regime. The UK Government designated six individuals under the Global Human Rights Sanctions Regulations 2020. These individuals are reportedly in charge of the Artic penal colony where Russian opposition figure Alexie Navalny died on February 16, 2024, after years of mistreatment by the Russian authorities. Those designated are (i) Aleksandr Vladimirovich Golyakov; (ii) Vadim Konstantinovich Kalinin; (iii) Sergey Nikolaevich Korzhov; (iv) Aleksandr Valerievich Obraztov; (v) Vladimir Ivanovich Pilipchik; and (vi) Vasiliy Alexandrovich Vydrin, all of whom are now subject to an asset freeze and travel ban.
• UK Government Amends One Entry on the Sanctions List under the Russia Regime. The UK Government made one variation to the entry for Vladimir Olegovich Potanin under the Russia sanctions regime. This individual remains subject to an asset freeze, travel ban, transport sanctions, prohibition of technical assistance related to aircraft and trust services sanctions.
• UK Government Amends One Entry on the Sanctions List under the Russia Regime. The UK Government made a variation to the entry for Oleg Alexandrovich Mashtalyar under the Russia sanctions regime. This individual remains subject to an asset freeze, trust services sanctions, and travel ban.
• UK Government Amends One Entry on the UK Sanctions List under the Russia Regime. The UK Government made a variation to the entry for Vladimir Aleksandrovich Dmitriev under the Russia sanctions regime. This individual remains subject to an asset freeze, travel ban, and trust services sanctions, and is now subject to transport sanctions.
• New Zealand Sanctions Those Involved in Russia Sanctions Evasion Procurement Networks. New Zealand sanctioned an additional 61 Russian individuals and entities, including those involved in sanctions evasion procurement networks. These designations include entities procuring technology for Russia’s defence industry and senior leaders of certain Russian banks. Those involved in the procurement of weapons from North Korea have also been sanctioned.
• Australia Imposes Further Targeted Financial Sanctions on Two-year Anniversary of Russia’s Invasion of Ukraine. Australia imposed further targeted financial sanctions and travel bans on 55 persons, and targeted financial sanctions on 37 entities. The new sanctions target those involved in Russia’s deportation of Ukrainian children from regions under temporary Russian control and targets in Russia’s defense, energy, media, and minerals sectors, as well as targets involved in Russia’s procurement networks in Belarus, Iran, and North Korea.
• Canada Imposes Additional Sanctions against Russia. Canada imposed sanctions on 10 individuals, including Putin’s aide and other senior officials of private and state-owned companies, who represent nodes of direct and indirect support of Russia’s full-scale invasion of Ukraine through finance, logistics and sanctions evasion. Canada also imposed sanctions on 153 entities, most of which are part of the Russian military-industrial complex, and who provide goods and services such as components for Kalibr missiles and drones, insurance and retail services to Russian soldiers and to the Russian Ministry of Defense. They also include entities providing oil transportation and logistics services to the Russian government.

January 2024

• The European Union added Russian state-owned diamond-mining company PJSC Alrosa and its CEO, Pavel Alekseevich Marinychev, to the EU’s sanctions list. The move complements an import ban on Russian diamonds that was part of the EU’s 12th package of economic and individual sanctions against Russia over its invasion of Ukraine.
• The European Union renewed for a further 6 months its restrictive measures in view of the Russian Federation’s continuing actions destabilizing the situation in Ukraine, until 31 July 2024.
• The European Union approved additional restrictive measures against four persons and one entity under the European Union’s Global Human Rights Sanctions Regime, in view of the continuing deterioration of the human rights situation in Russia.
• The United States OFAC designated a shipping company, Hennesea Holdings Limited, linked to a price cap violation and 17 vessels. This action demonstrates US commitment to prohibit the import of crude oil and petroleum products of Russian Federation origin as part of an international coalition of countries, including the G7, the EU, and Australia.
• US, Australia, and the UK Sanction Russian Cyber Actor: On January 23, OFAC, in coordination with Australia and the United Kingdom, designated Alexander Ermakov, a cyber actor who played a pivotal role in the 2022 ransomware attack against Medibank Private Limited, an Australian healthcare insurer.
• US Department of State Acts in Response to DPRK-Russia Ballistic Missile Transfers and Testing: The Department of State imposed sanctions under E.O. 14024 on three Russian entities and one individual involved in the transfer and testing of Democratic People’s Republic of Korea (DPRK) ballistic missiles for Russia’s use against Ukraine. The State Department also identified four aircraft, owned by the already US-designated Command of the Military Transport Aviation, as blocked property. This action follows the US Department of State’s statement, with the Ministers of Foreign Affairs of several countries, including the G7, condemning the DPRK’s export and Russia’s procurement of DPRK ballistic missiles, as well as Russia’s use of these missiles against Ukraine on December 30, 2023, and January 2, 2024.
• UK Government Amends One Entry on the UK Sanctions List under the Russia Regime: On January 15, the UK Government amended one entry on the Russia sanctions list relating to Svyatoslav Evgenievich Ostrovsky.
• UK Court Rejects Graham Phillips’ Sanctions Act Challenge: On January 12, the Administrative Court gave judgment in England’s first ever case to consider the relationship between financial sanctions and freedom of expression. Graham Phillips was sanctioned by the United Kingdom in July 2022 for producing propaganda videos from the Donbas region in Ukraine which were in favour of Russia and their invasion of Ukraine. Graham Phillips had challenged the UK’s decision to designate him on the grounds that (i) the UK Government did not have the power to impose financial sanctions on a person on account of their political views, and (ii) his designation was a disproportionate restriction on his right to freedom of expression. The challenge was rejected. Among other things, the Court founds that (i) Mr Phillips’ video content was propaganda in favor of the Russian invasion of Ukraine; (ii) the UK Government has the power to impose sanctions on an individual who supports or promotes policies or actions which destabilize Ukraine or undermine its territorial integrity, sovereignty and independence, including through acts of “expression”, and (iii) the financial sanctions imposed on Phillips were proportionate.
• UK Makes Joint Statement with Other Nations on Russia’s Procurement and Use of Weapons from the DPRK: On January 10, the UK, along with France, Japan, Malta, the Republic of Korea, Slovenia, Ukraine, and the United States, issued a joint statement asserting that Russia’s procurement and use of weapons from the DPRK violates UN Security Council Resolutions. In the statement, the signatory nations allege that Russia’s 30 December 2023 and 6 January 2024 attacks on Ukraine were carried out with the use of weapons imported from the DPRK, and condemns these actions as they violate several UN Security Council resolutions that prohibit UN Member States from procuring arms from the DPRK and prohibit the DPRK from exporting arms.
• Ukraine Extends Sanctions to 57 Individuals and 134 Companies: The sanction lists were updated based on the Orders of the President of Ukraine No. 850/2023 and 851/2023, as well as No. 877/2023.
• Ukraine Adds 2 Companies to the List of the Sponsors of War: Ukrainian Anti-Corruption Bureau added the Swedish company Elektriska Svetsnings-Aktiebolaget (ESAB) and the Lithuanian company Viciunai Group (VICI) to the list of international sponsors of war. It is reported that both companies remained in the Russian market and continue to pay significant contributions into the Russian budget.

December 2023

• The Biden administration issues a new executive order taking additional steps to sanction Russia. The amendments affect earlier executive orders, including 14024 (April 15, 2021), 14066 (March 8, 2022), 14039 (August 20, 2021), 14068 (March 11, 2022), and 14071 (April 6, 2022). The US Treasury issues a new guidance in line with the new executive order.
• Switzerland implements a new round of sanctions mirroring the European Union’s 12th sanctions package of December 18, 2023.
• The US Treasury tightens the price cap for Russian oil aimed at strengthening the attestation and recordkeeping processes for certain covered service providers and sanctions a Russian government-owned ship manager as well as several obscure oil traders.
• Japan announces sanctions on numerous individuals and entities.
• The European Union adopts its 12th package of sanctions against Russia. The latest sanctions feature additional export and import restrictions, sanctions on individuals, financial sanctions, and more.
• Japan announces sanctions on numerous individuals and entities, as well as additional restrictions on imports and exports to Russia.
• The UK government legislates further sanctions on goods, technology, and sources of funding that could support Russia’s war effort.
• The US Treasury sanctions over 100 individuals and entities in numerous third countries for the facilitation and procurement of weapons and technologies to Russia.
• Canada sanctions 30 Russian nationals who ran in the Kremlin-organized sham elections on September 8-10, 2023, on the Russian-occupied territory of Kherson Oblast in Ukraine.
• The UK government announces new sanctions targeting people and groups that are supplying and funding Russia’s war machine.
• Canada amends its sanctions regulations to prohibit the direct import of diamond and diamond-related products originating in Russia.
• The US Treasury sanctions numerous individuals and entities in Belarus for complicity in Russia’s war on Ukraine. Treasury also sanctions 9 entities and 5 individuals based in Russia, Belgium, Cyprus, Sweden, Hong Kong, and the Netherlands for procuring electronics with military applications for Russian end-users.
• The US Treasury sanctions 3 entities for violating the price cap set by the Price Cap Coalition (G7 countries, the European Union, and Australia) by using Coalition service providers to transport Russian crude oil purchased for over $60 per barrel.

November 2023

• The US Department of State sanctions numerous Russian military officials for their involvement in gross violations of human rights against civilians in Ukraine.and 12 entities pursuant to E.O. 14024.
• The US Treasury designated numerous individuals and entities pursuant to Russia-related Executive Order 14024 (as well as Western Balkans-related E.O. 14033). In a coordinated action, the US Department of State also designated 2 individuals and 12 entities pursuant to E.O. 14024.
• The US Treasury sanctions 3 entities for using Price Cap Coalition (G7 countries, the European Union, and Australia) service providers to transport Russian crude oil purchased for over the Coalition’ $60 per barrel price cap.
• Canada sanctions numerous individuals and entities for disseminating Russian disinformation and propaganda about the ongoing invasion of Ukraine.
• The UK government announces sanctions targeting individuals and entities operating in and supporting Russia’s gold, oil, and strategic sectors.
• The US Treasury sanctions entities in China, Turkey, and the United Arab Emirates for sending high-priority dual use goods to Russia, as well as 7 Russian banks and other individuals and entities. The US State Department issues sanctions that affect over 90 entities for sanctions evasion and also target Russia’s future energy capabilities.

October 2023

• Deeply concerned by the devastating effects of the current Russian military aggression against Ukraine, the Egmont Group of Financial Intelligence Units (FIUs) suspends the membership of Russia’s FIU Rosfinmonitoring.
• The US Treasury sanctions 11 individuals, 8 entities, and 1 vessel based in Iran, Hong Kong, China, and Venezuela enabling Iran’s ballistic missile and unmanned aerial vehicle (UAV) programs, some of which are being used in Russia’s invasion of Ukraine.
• The US Treasury sanctions two ship owners for violating the price cap set by the Price Cap Coalition (G7 countries, the European Union, and Australia) by transporting oil purchased for over $60 per barrel.
• The US Commerce Department adds 42 companies from China as well as 7 from other countries (i.e., Estonia, Finland, Germany, India, Turkey, the United Arab Emirates, and the United Kingdom) to the Entity List for supporting Russia’s military and defense industrial base, including through supplying US semiconductors.

September 2023

• Norway announces that Russian-registered passenger cars with nine or fewer seats can no longer be brought into Norway, even temporarily.
• The United Kingdom sanctions Russian officials involved in recent sham elections in the Ukrainian regions of Kherson, Zaporizhzhia, Donetsk, Luhansk, and in illegally annexed Crimea.
• Switzerland implements a new sanctions framework targeting Iran’s provisions of unmanned aerial vehicles (UAVs) to Russia, mirroring the European Union’s sanctions framework for Iran introduced on July 20, 2023.
• The US Treasury sanctions 5 entities and 2 individuals based in Iran, China, Hong Kong, Turkey, and the United Arab Emirates involved in the procurement of sensitive parts for Iran’s one-way attack unmanned aerial vehicle (UAV) program being used in Russia’s invasion of Ukraine.
• The US Commerce Department adds to the Entity List 28 companies, including 11 from China and 5 from Russia, for supporting Russia’s military and defense industrial base, including through parts for drones.
• Australia extends punitive 35 percent tariffs on goods imported from Russia and Belarus first imposed in April 2022 for two more years, until October 2025.
• Canada sanctions 42 individuals and 21 entities connected to Russia’s illegal and forcible mass transfer of Ukrainian minors, Russian disinformation, and Russia’s nuclear sector.
• The US Treasury imposes nearly 100 sanctions on Russian elites and Russia’s industrial base, financial institutions, and technology suppliers.The US State Department also imposes over 70 sanctions on Russian individuals and entities.
• The European Union imposes an asset freeze and travel ban on 6 individuals responsible for serious human rights violations in Russia and Ukraine, including violations of the right to freedom of opinion and expression.

August 2023

• The US Commerce Department issues a Temporary Denial Order suspending the export privileges of 3 individuals and 4 companies for supplying illicit goods to the Russian military.
• Switzerland adopts the remaining sanctions against Belarus adopted by the European Union on August 3.
• The US State Department imposes sanctions and visa restrictions on individuals and entities connected with the forcible transfer and deportation of Ukrainian children.
• Canada sanctions 4 individuals and 29 entities connected to Russia’s military-industrial complex, financial institutions, and nuclear sector.
• Canada sanctions 15 individuals and 3 entities in Russia.
• Switzerland adopts some of the sanctions against Belarus that the European Union imposed on August 3.
• The US Treasury sanctions 4 members of Russia’s financial elite.
• The US Treasury sanctions 8 individuals and 5 entities in Belarus for complicity in Russia’s war in Ukraine, among other reasons.
• The United Kingdom sanctions individuals and businesses in Turkey, Dubai, Slovakia, Switzerland, Belarus, and Iran who are supporting Russia’s war on Ukraine.
• Canada announces 3 sets of amendments to its sanctions regime impacting Russia (one, two, three) and sanctions on 9 individuals and 7 entities in Belarus.

July 2023

• The United Kingdom sanctions 6 individuals involved in the trial of Vladimir Kara-Murza, a dual British-Russian national who is facing 25 years in a penal colony and is being persecuted by the Russian regime for his anti-war stance.
• The European Union sanctions 7 Russian individuals and 5 entities responsible for conducting the digital information manipulation campaign Recent Reliable News (RRN) that disseminates propaganda in support of Russia’s war against Ukraine.
• The US Treasury sanctions 3 Malian transition government and military officials for facilitating the deployment and expansion of activities in Mali by the Wagner Group, which has carried out combat operations in Russia’s war on Ukraine.
• New Zealand announces sanctions targeting Russian military support and the Belarusian financial sector.
• The US Treasury and Department of State take additional measures to inhibit Russia’s access to products that support its military and war efforts; reduce its revenue from the metals and mining sector; undermine its future energy capabilities; degrade its access to the international financial system; and starve Russia of G7-produced technology needed for its technology, aerospace, and defense sectors.
• The United Kingdom sanctions 13 individuals and businesses linked to the actions of the Wagner Group.
• Canada announces sanctions on 39 individuals and 25 entities, including those linked to the Wagner Group and Russia’s nuclear sector, and those from Russian cultural and education sectors that support the Kremlin’s efforts to “Russify” Ukrainian culture.
• The United Kingdom announces new sanctions and travel bans in response to Russia’s forced deportation of Ukrainian children.
• Russia pulls out of a UN-brokered arrangement that allowed Ukraine to export grain globally through the Black Sea.
• The Norwegian government looks to establish a new agency for export control and sanctions, given the increasingly complex situation concerning sanctions and export regulations, particularly as a result of the war against Ukraine.

June 2023

• Japan bans exports of construction and engineering services to Russia.
• The United Kingdom passes a law that restricts exports of legal services to wealthy individuals and big businesses linked to the Russian regime.
• Switzerland implements a new round of sanctions mirroring the European Union’s eleventh sanctions package ofJune 23, 2023.
• The US Treasury sanctions 4 companies and 1 individual connected to the Wagner Group.
• Warlord Yevgeny Prigozhin (Wagner Group) briefly attempts a coup in Russia before reversing course.
• The European Union adopts its eleventh package of sanctions against Russia. The latest sanctions feature additional export and import restrictions, sanctions on individuals, financial sanctions, and more.
• The United Kingdom announces new legislation allowing sanctions on Russia to remain until compensation is paid to Ukraine.
• The US Department of Commerce issues a temporary denial order suspending export privileges for the Aratos Group and its president for allegedly providing support to Russian intelligence services.
• The United Kingdom introduces new legislation banning imports of gold, cement, wood, and rubber from Belarus and also blocking exports to Belarus of banknotes and machinery, alongside goods, technologies, and materials that could be used to produce chemical and biological weapons.
• The Nova Kakhovka Dam in Ukraine was destroyed, causing extensive flooding and damage along the Dnieper River in Kherson Oblast. The dam was under the control of the Russian military.
• The US Treasury sanctions 7 members of a Russian intelligence-linked malign influence group for their role in the Russian government’s campaigns of destabilization and continued malign influence in Moldova.

May 2023

• The United States extends the Section 232 exemption on Ukrainian steel by one year.
• The United Kingdom agrees to extend the current suspension of trade remedy measures on imports of steel from Ukraine for another 12 months.
• Japan sanctions 17 Russian individuals and 78 organizations and bans exports to 80 organizations, the exports of certain goods to Russia that strengthen its industrial base, and the provision of building or engineering services to Russia.
• G7 leaders meet in Hiroshima, Japan and issue a communique in which they commit to “increasing the costs to Russia and those supporting its war efforts.”
• The US Treasury sanctions 22 individuals and 104 entities, targeting those attempting to circumvent or evade sanctions and other economic measures against Russia, the channels Russia uses to acquire critical technology, its future energy extraction capabilities, and its financial services sector. The US Commerce Department expands export controls by adding 71 entities to the Entity List, primarily for supporting Russia’s military and defense sectors. The US Department of State is designating 18 entities involved in expanding Russia’s future energy production and export capacity.
• The UK government sanctions 86 individuals and entities, targeting Russia’s theft of Ukrainian grain, advanced military technology, and remaining revenue sources.
• Australia announces sanctions targeting 21 entities and 3 individuals as well as an export ban on all machinery and related parts to Russia and areas temporarily under Russian control, targeting sectors of economic and strategic significance to Russia and aiming to slow Russia’s war machine.
• Canada sanctions 17 individuals and 18 entities in Russia. Canada also listed 30 individuals and 8 entities involved in Russia’s ongoing human rights violations, including the transfer and custody of Ukrainian children in Russia.
• The United Kingdom bans imports of Russian diamonds and Russian-origin copper, aluminum, and nickel.
• The Department of Commerce issues a temporary denial order suspending export privileges for 3 companies and 2 Russian nationals living in Florida for diverting civilian aircraft parts to Russia.

April 2023

• Pursuant to Executive Order 14078, the US State Department sanctions Russia’s Federal Security Service (FSB) and Iran’s Islamic Revolutionary Guard Corps Intelligence Organization (IRGC-IO) for the wrongful detention of US nationals, including Evan Gershkovich. The Treasury also sanctions four senior officials in the IRGC-IO.
• Switzerland sanctions the Wagner Group and RIA FAN, mirroring EU sanctions of April 13.
• Canada, France, Japan, the United Kingdom, and the United States announce an alliance aimed at displacing Russia from the international nuclear energy market to undermine its grip on supply chains.
• The European Union sanctions the Wagner Group, a private military entity, and RIA FAN, a Russian media company involved in pro-government propaganda and disinformation on Russia’s war on Ukraine.
• Three US government bodies sanction financial facilitators and sanctions evaders. The US Treasury sanctions 25 individuals and 29 entities. The Department of State sanctions several entities operating in the defense sector of the Russian economy and supporting Russia’s war against Ukraine, as well as additional entities associated with Russia’s State Atomic Energy Corporation (Rosatom). The US Department of Commerce adds 28 entities to its Entity List.
• The United Kingdom sanctions family members, other individuals, and companies in a crackdown on enablers of oligarchs Roman Abramovich and Alisher Usmanov.
• Canada sanctions 14 individuals, largely at Russian companies that provide military services, and 34 entities that were largely military technology and logistics companies.
• Norway implements a new round of sanctions mirroring the European Union’s tenth sanctions package of February 25, 2023.
• Finland formally joins NATO.

March 2023

• New Zealand sanctions political and military figures from Russia and Belarus.
• The US Treasury sanctions Slovakian national Ashot Mkrtychev for attempting to facilitate an arms deal between North Korea and Russia.
• Switzerland implements a new round of sanctions mirroring the European Union’s tenth sanctions package of February 25, 2023.
• Wall Street Journal journalist, Evan Gershkovich, an American citizen, is arrested in Russia and charged with spying.
• The US Treasury sanctions three entities and nine individuals in Belarus in part to hold the Lukashenka regime to account for its complicity in Russia’s war against Ukraine.
• The UK and Ukraine sign a new Digital Trade Agreement. The UK also pledges to extend the removal of tariffs on all Ukrainian products until March 2024.
• Ukraine sanctions 300 individuals and 141 entities, targeting the Russian military as well as people contributing to the Russian aggression against Ukraine from Russia, Iran, Syria and the United Arab Emirates.
• The Council of the European Union decides to prolong for another six months sanctions imposed earlier on 1,473 individuals and 205 entities.
• Canada bans imports of steel and aluminum from Russia.
• US Treasury sanctions three individuals for their involvement in serious human rights abuse against human rights defender, prominent Russian opposition leader, author, and historian Vladimir Kara-Murza.

February 2023

• Following the one-year anniversary of Russia’s brutal invasion of Ukraine, Japan announces new sanctions on Russian individuals and companies and new export controls.
• The EU adopts its tenth package of sanctions against Russia. The latest sanctions feature additional export restrictions–including on Iranian drone manufacturers–import restrictions, sanctions on individuals, financial sanctions, and more.
• New Zealand sanctions Iranians supplying drones to Russia.
• At the one-year mark of Russia’s brutal invasion of Ukraine, the United States announces new sanctions, including higher tariffs on Russian imports (including steel and aluminum). The US Treasury also sanctions Russia’s metals and mining sector, military suppliers, 22 individuals, and identifies targets involved in sanctions-evasion efforts.
• At the one-year mark of Russia’s brutal invasion of Ukraine, the United Kingdom announces fresh sanctions, including new export bans on any item Russia has used on the battlefield to date and sanctions on additional Russian and Iranian individuals.
• At the one-year mark of Russia’s brutal invasion of Ukraine, G7 Leaders meet with Ukraine’s President Volodymyr Zelenskyy to reaffirm their unwavering support for Ukraine “for as long as it takes.”
• At the one-year mark of Russia’s brutal invasion of Ukraine, New Zealand sanctions 87 Russian individuals.
• Canada sanctions an additional 129 Russian individuals and 63 entities.
• The European Union prolongs its February 23, 2022 restrictive measures made in response to the illegal recognition, occupation, or annexation by the Russian Federation of certain non-government controlled areas of Ukraine until February 24, 2024.
• Switzerland implements price caps on Russian refined oil products aligned with those adopted by the European Union and G7 countries.
• Norway implements price caps on Russian refined oil products aligned with those adopted by the European Union and G7 countries.
• Ukraine imposes sanctions on Russia’s state-owned Rosatom and 199 affiliated companies.
• G7 countries, the European Union, and Australia implement price caps on Russian refined oil products. (See also Japan, UK.)
• The US Treasury and the State Department sanction the board of directors of an Iranian unmanned aerial vehicle manufacturer for supplying drones to Russia.
• Canada sanctions 38 individuals and 16 entities involved in Russia’s disinformation and propaganda actions.
• The European Union extends its tariff waiver on imports from Ukraine for another year.
• The US Treasury sanctions 22 individuals and entities across multiple countries related to a sanctions evasion network supporting Russia’s military-industrial complex.

January 2023

• The US Commerce Department restricts access to foreign-made components to seven Iranian entities supplying drones to Russia.
• Norway implements a new round of sanctions mirroring the EU’s ninth sanctions package of December 16, 2022.
• The European Union prolongs the restrictive economic measures targeting specific sectors of the Russian economy since 2014 by six months, until July 31, 2023.
• Japan modifies its sanctions by adding goods to an export ban list and freezing the assets of Russian officials and entities.
• The US Treasury and the State Department sanction eight individuals, 16 entities, and four aircraft and designate Russia’s paramilitary Wagner Group as a transnational criminal organization, targeting the infrastructure that supports battlefield operations in Ukraine.
• The United States, Germany, and other countries announce they are sending tanks to Ukraine.
• Switzerland implements a new round of sanctions mirroring the EU’s ninth sanctions package of December 16, 2022.
• Ukraine sanctions 119 Russian artists and cultural figures for their support of the war.
• The US Treasury sanctions six executives and board members of a key Iranian defense manufacturer of unmanned aerial vehicles (UAVs), as well as the director of an organization responsible for overseeing Iran’s ballistic missile programs, for supporting Russia’s attacks on Ukraine.

December 2022

• Vladimir Putin signs a decree banning Russian oil sales effective February 1 under contracts that comply with the $60 price ceiling imposed by the G7 that largely went into effect December 5. However, the decree includes a loophole that Putin “may grant special permission” to sell oil in certain circumstances, even if purchasers comply with the cap.
• The US State Department sanctions 10 Russian naval entities.
• The EU adopts its ninth package of sanctions against Russia. Sanctions include bans on exports of drone engines, dual-use goods used for civilian and military purposes, investments in mining, transacting with the Russian Regional Development Bank, the provision of advertising, market research, and public opinion polling services. The EU also suspended broadcasting licenses of four additional Russian outlets and sanctioned an additional 141 individuals and 49 entities.
• Switzerland adopts further sanctions against Russia, aligning with the EU’s price cap on Russian crude oil and petroleum products agreed on December 3.
• The US Departments of Treasury and State combine to sanction a number of Russian financial services firms and other Russian individuals.
• New Zealand sanctions three Iranian individuals and one entity involved in the manufacture and supply of drones to Russia.
• The UK imposes travel bans and sanctions on senior Russian military commanders, and Iranian businessmen and officials involved in the production and/or supply of drones used by Russia in its attacks on Ukraine.
• New Zealand sanctions 23 individuals behind disinformation campaigns that support Russia’s war effort.
• As part of a broader announcement of sanctions marking Human Rights Day and International Anti-Corruption Day, US Treasury sanctions four individuals who were directly involved in Russia’s filtration operations, whereby Ukraine’s civilians are subjected to interrogations and searches and forced to hand over personal data, nominally in order to ascertain any connections to Ukraine’s military or government. US State Department also sanctions three Russian entities involved in a deal with Iran to acquire unmanned aerial vehicles (UAVs) to potentially deploy in the war with Ukraine.
• The UK sanctions a number of Russians involved in the Ukraine war under a new list of sanctions on corrupt political figures, human rights violators, and perpetrators of conflict-related sexual violence around the world.
• Norway aligns with EU sanctions by adopting the $60 per barrel oil price cap implemented by the EU, G7 countries, and Australia on December 5.
• Australia sanctions three Iranians and one Iranian business for supplying drones to Russia for use against Ukraine.
• Canada sanctions 33 individuals connected to the systematic suppression of protests and opposition to Russia’s war in Ukraine, forced mobilization and anti-democratic decisions of the Russian government, as well as 6 federal Russian entities involved in the investigation, prosecution, and detention of Russian citizens who oppose or criticize Russia’s policies in Ukraine.
• G7 countries, the EU, and Australia implement a price cap of $60 per barrel on Russian-origin seaborne crude oil by creating an exception from restrictions on maritime services. (See also Canada, Japan, UK.)

November 2022

• The UK sanctions 22 Russian officials and 10 governors and regional heads who have promoted and enforced the conscription of citizens to fight in Russia’s war in Ukraine.
• The UK and Ukraine agree to a new Digital Trade Agreement, including the free flow of data and cybersecurity cooperation.
• The European Council adds the violation of restrictive measures on Russia to the list of ‘EU crimes’ included in the Treaty on the Functioning of the EU to enforce sanctions more consistently throughout the EU and deter attempts to circumvent or violate sanctions.
• Switzerland adopts further sanctions against Russia, aligning with the EU’s eighth package of sanctions implemented on October 6.
• New Zealand imposes financial sanctions and travel bans on additional elites from Russia and Belarus.
• US Treasury sanctions firms and individuals involved in the production or ongoing transfer to Russia of Iranian unmanned aerial vehicles (UAVs) used to attack Ukraine. US State Department concurrently sanctions other Russian and Iranian firms pursuant to E.O. 14024.
• A missile lands in Poland, killing two, risking a triggering of NATO’s active engagement in the Russia-Ukraine war. The next day, NATO indicates it was likely accidental Ukrainian friendly fire, stating “we have no indication that this was the result of a deliberate attack.”
• The US Treasury and US State Department sanction 14 individuals and 28 entities engaged in a transnational network procuring technology that supports the Russian military-industrial complex.
• Russia bans entry of 100 Canadians, including Jim Carrey and Margaret Atwood, as well as 200 Americans, including White House Press Secretary Karine Jean-Pierre and relatives of President Biden.
• Canada sanctions 23 individuals who are members of the Russian justice and security sector, including police officers and investigators, prosecutors, judges, and prison officials involved in human rights violations in Russia against opposition leaders.
• The United Kingdom adopts legislation preventing countries from using the UK’s services to transport Russian oil.
• The United Kingdom imposes travel bans, asset freezes, and transport sanctions on 4 oligarchs who have enabled Putin to mobilize Russian industries to support his military effort.
• Russia rejoins the UN-brokered grain deal with Ukraine that it had left on October 29.
• Switzerland freezes assets and bans travel for 3 Iranian individuals and one entity for providing drones used in Russian aggression, adopting the EU sanctions imposed on October 20.

October 2022

• The UK adopts legislation that expands the scope of existing sanctions and introduces new restrictions against Russia, impacting financial sanctions, as well as imports and exports.
• New Zealand sanctions New Zealand sanctions 14 individuals and 7 entities, including military personnel, defense entities and executives, Russian- directed disinformation outlets, and a paramilitary organization and its senior commanders.
• Russia adds 11 British Overseas Territories to its unfriendly countries list, including Bermuda, British Antarctic Territory, British Indian Ocean Territory, Cayman Islands, Falkland Islands, Montserrat, Pitcairn Islands, St. Helena, Ascension and Tristan da Cunha Islands, South Georgia and the South Sandwich Islands, Akrotiri and Dhekelia, and the Turks and Caicos Islands.
• Russia suspends its participation in the UN-brokered grain deal with Ukraine for an “indefinite term” indicating it cannot “guarantee the safety of civilian ships.”
• Canada modifies sanctions impacting 35 individuals who are senior executives of Russian energy entities already sanctioned and 6 entities involved in the energy sector.
• Norway introduces new sanctions, aligning its laws with the EU’s eighth package of sanctions announced on October 6, including sanctions on 30 individuals and 7 entities, and new import and export restrictions.
• The UK freezes assets and imposes a travel ban on a number of Iranian individuals and businesses responsible for supplying Russia with kamikaze drones that attacked Ukraine.
• The EU sanctions 3 Iranian individuals (with asset freezes and travel bans) and one entity for providing drones used in Russian aggression.
• The US Treasury sanctions a Russian network that procured military and sensitive dual-use technologies from US manufacturers and supplied them to Russian end-users. In a concurrent action, the US Department of Justice unseals an indictment charging 5 Russian nationals and 2 oil traders in a global sanctions evasion and money laundering scheme.
• The US Department of Commerce issues a temporary denial order against Russia’s Ural Airlines for operating in apparent violation of US export controls on Russia. Ural will no longer be able to participate in transactions of products subject to US export regulations.
• Canada sanctions an additional 34 individuals and 1 entity for involvement in Russian propaganda.
• Switzerland imposes financial sanctions and travel bans on 30 more individuals and financial sanctions on seven entities related to Russia’s invasion of Ukraine and adjusts sanctions already applied to the Russian annexed areas of Donetsk and Luhansk to the areas of Zaporizhzhia and Kherson no longer controlled by the Ukrainian government.
• New Zealand imposes financial sanctions targeting 51 oligarchs and 24 Russian-backed office holders in the Russian annexed Donetsk, Luhansk, Kherson, and Zaporizhzhia regions of Ukraine and imposes new bans on exports and imports of luxury goods like NZ wine and seafood and Russian vodka and caviar, as well as oil, gas, and related production equipment. New Zealand also extends its additional 35 percent tariff on Russian imports until March 2025.
• Japan imposes financial sanctions on 58 Russian individuals, 9 Russian entities, and 23 other individuals responsible for the annexation of the Donetsk, Luhansk, Kherson, and Zaporizhzhia regions of Ukraine.
• The EU adopts its eighth package of sanctions against Russia. Sanctions include implementation of the price cap on Russian oil (agreed with the G7 and announced on September 2), additional import restrictions and export controls, and expansion of the restrictions introduced on February 23 to cover Zaporizhzhia and Kherson.
• Australia imposes financial sanctions and travel bans on 28 Russian-appointed separatists, ministers, and senior officials.

September 2022

• The US Department of Commerce expands export controls by adding 57 firms in Russia and the Crimea region of Ukraine to the Entity List. Commerce also issues new guidance warning that export controls also apply to third countries that may be seeking to replenish (“backfill”) technologies subject to export controls imposed by the United States and its 37 partners that they previously sold to Russia.
• The US Treasury sanctions 14 persons in Russia’s military-industrial complex, including two international suppliers, three key leaders of Russia’s financial infrastructure (including Elvira Nabiullina, the governor of Russia’s central bank), immediate family members of senior Russian officials, and 278 members of Russia’s legislature.
• UK extends export ban to new services, like IT consultancy, architectural, and engineering services, and almost 700 goods.
• After organizing sham referendums in southeastern Ukraine, Russia’s President Putin annexes Donetsk, Luhansk, Kherson, and Zaporizhzhia.
• In an enforcement action, the US Justice Department unseals an indictment charging a US citizen and three Russian citizens with violating new US sanctions imposed earlier this year.
• Canada lists an additional 43 individuals who are family members of already listed oligarchs, additional oligarchs, or financial elites.
• Australia prohibits the import of Russian gold after September 30, 2022.
• New Zealand sanctions 19 additional members of Putin’s inner circle.
• UK announces 92 sanctions in response to the Russian regime imposing sham referendums in 4 regions of Ukraine.
• Japan bans exports of chemical weapons-related goods to Russia and adds 21 Russian organizations, including science labs, as targets of its export bans.
• Russia launches four-day “sham” referendums across southeastern Ukraine with the aim of legitimizing the ultimate annexation of Donetsk, Luhansk, Kherson, and Zaporizhzhia.
• Defense Minister Sergei Shoigu announces Russia will draft 300,000 reservists to support its military campaign in Ukraine.
• Germany places three Russian Rosneft-owned refineries located in Germany under the trusteeship of the country’s federal energy regulator and introduces measures to ensure refineries can also receive oil from routes other than the Druzhba pipeline from Russia.
• Australia issues two amendments to its sanctions imposed on Russian individuals.
• At a meeting with President Xi Jinping in Uzbekistan, Russian President Putin acknowledges that Xi had “concerns” about the situation in Ukraine, calling into question their previous “no limit” statement of the two countries’ friendship. At the 51st regular session of the UN Human Rights Council in Vienna, China opposes the “illegal unilateral sanctions” imposed on Russia by the US and others.
• The US Treasury sanctions an additional 22 individuals and 2 entities, including Russians and others operating on behalf of Russia in Russian-occupied territories.
• The EU extends for an additional six months travel restrictions, asset freezes, and financial sanctions already imposed on 1,206 individuals and 108 entities, many of which are targeted due to Russia’s war against Ukraine.
• The US Treasury publishes preliminary guidance on implementation of the G7 price cap on Russian seaborne oil shipments announced September 2. Policy would allow otherwise banned maritime service providers, e.g., insurance, brokering, finance, if the Russian oil transaction price is below a G7-set cap.
• Russia states it will not fully resume natural gas shipments to Europe until the “collective west” lifts its sanctions. Russia argues the sanctions are preventing repairs to Nord Stream 1 pipeline, but the EU disputes the justification. (Russia had indefinitely suspended shipments through the pipeline on September 2 after the G7 price cap announcement.)
• Russia bars Americans Ben Stiller, Sean Penn, and 23 others from traveling to Russia.
• Group of 7 (G7) finance ministers agree to finalize and implement a price cap on Russian crude oil and petroleum products. The measure would prohibit the maritime transportation of Russia’s oil and petroleum exports globally unless the products are purchased at or below a certain price.

August 2022

• Switzerland adjusts its sanctions of June 29, 2022 by adopting a ban on awarding public procurement contracts to Russian nationals, organizations, or institutions.
• The UK and Ukraine announce they have commenced talks on a new digital trade agreement to help Ukraine rebuild its economy.
• New Zealand sanctions more officials installed by Russia in separatist regions in now occupied areas of Ukraine.
• Canada sanctions an additional 31 Russian individuals and 1 defense sector entity.
• The EU sanctions pro-Russian former President of Ukraine Viktor Fedorovych Yanukovych and his son Oleksandr Viktorovych Yanukovych.
• Switzerland bans imports of Russian gold to align itself with the EU sanctions imposed on July 21 and implements “the most urgent measures in terms of time and substance,” including sanctions on Sberbank, 54 individuals, and 9 additional organizations and entities.
• The US Treasury sanctions Kremlin-connected elites, including President Putin’s alleged girlfriend Alina Maratovna Kabaeva; a major multinational company; a sanctions evasion operation; and a yacht.
• Canada sanctions an additional 43 Russian individuals and 17 entities, including military officials involved in the Bucha massacre and entities in the defense sector directly or indirectly supporting the Russian military.
• New Zealand bans exports of goods and services to the Russian Armed Forces and other defense entities.

July 2022

• The US Treasury and Department of Justice sanction two individuals and four entities supporting Russia’s attempts to manipulate and destabilize the United States and its allies and partners, including Ukraine.
• The UK sanctions additional individuals, including Russian-imposed prime minister and first deputy chairman of the so-called Donetsk People’s Republic and Luhansk People’s Republic, for undermining Ukrainian territorial integrity, as well as 29 regional governors from across Russia who had been directed by the Kremlin to transfer funds to Donetsk and Luhansk.
• The EU renews economic sanctions over Russia’s military aggression against Ukraine for another six months, until January 31, 2023.
• Japan revises its July 5 ban on imports of gold from Russia.
• Russia and Ukraine sign an agreement in Istanbul to unblock grain exports from ports on the Black Sea to help ease the global food crisis. (Ukraine’s first grain shipment leaves Odesa on August 1.)
• The EU implements G7 commitments by banning imports of gold from Russia, clarifying and expanding on existing export controls, and sanctioning an additional 54 individuals and 10 entities.
• Russia bans 384 Japanese lawmakers from traveling to Russia.
• Canada bans services exports to the Russian oil, gas, chemical, and manufacturing industries as well as 8 new Russian industries.
• Canada implements G7 commitments by banning imports of gold from Russia, imposing financial sanctions on 29 individuals and 15 entities involved in Russian disinformation activities, and more.
• Japan implements G7 commitments by banning imports of gold from Russia, exports to 65 Russian and 25 Belarusian organizations, and provision of certain financial services to Russia. It also imposes sanctions on a number of new individuals.
• The UK announces various sanctions against Russia will be extended to Belarus, including import and export bans and restricted access to UK financial services.
• Australia announces it will cut tariffs to zero on all imports from Ukraine. It also announces it will impose financial sanctions and travel bans on 16 additional Russian ministers and oligarchs and ban imports of Russian gold.
• New Zealand bans imports of Russian gold.

June 2022

• The EU renews for another year (until June 23, 2023) previously imposed sanctions related to Russia’s 2014 annexation of Crimea and the city of Sevastopol.
• The UK sanctions more Russian individuals, including Russian Children’s Rights Commissioner Maria Lvova-Belova, for the forced transfer and adoption of Ukrainian children, as well as Russian organizations responsible for supplying aircraft parts to the Myanmar Armed Forces.
• The US Treasury sanctions two key supporters of the ethnically motivated violent extremist group known as the Russian Imperial Movement (RIM).
• Switzerland sanctions Russia and Belarus by adopting the EU’s sixth round of sanctions adopted on June 3.
• Ukraine imposes sanctions on President Putin and 34 other Russian individuals. The country also sanctions 261 heads of Russian higher education institutions and suspends cultural exchanges, scientific cooperation, educational and sports contacts, and entertainment programs with 236 Russian higher education institutions.
• Canada prohibits exports of a range of services to Russia.
• Japan announces new measures including freezing the assets of two Russian banks, one Belarusian bank, and banning exports of more goods that strengthen Russia’s industrial base, including trucks, dump trucks, and bulldozers.
• New Zealand imposes financial sanctions on Gazprom as well as dozens of Russian military and industrial corporations.
• Russia bars US Treasury Secretary Janet Yellen, US Trade Representative Katherine Tai, and dozens of other Americans, including media executives, from traveling to Russia.
• The EU adopts its sixth major package of sanctions that eventually bans imports of Russian crude oil and petroleum products with limited exceptions (announced May 30-31), bans SWIFT for three Russian banks and one Belarusian bank, suspends broadcasting in the EU for three Russian media outlets, and sanctions an additional 65 individuals and 18 entities, including banning travel and freezing assets of individuals responsible for atrocities in Bucha and Mariupol.
• Russia bans travel entry of 41 Canadians, including top defense officials.
• The US Treasury, State Department, and Department of Commerce freeze assets of more Russian individuals and impose financial sanctions as well as export controls by adding more parties to the Entity List.

May 2022

• The EU imposes its sixth major package of sanctions, which will eventually ban imports of Russian crude oil and petroleum products, with a temporary exception for some crude oil delivered by pipeline.
• Canada sanctions additional Russian individuals and financial institutions.
• The US Treasury starts blocking Russia from paying American bondholders by letting an exceptions license issued on April 6 expire.
• Russian energy company Gazprom cuts off natural gas exports to Finland for failing to pay in rubles.
• Russia bars President Biden and 962 other Americans from traveling to Russia.
• The UK sanctions additional Russian individuals reportedly close to President Putin, including his ex-wife and cousins.
• Russia blocks transactions with 31 foreign energy companies, including ex-subsidiaries of Gazprom in the EU, as well as firms in the US and Singapore.
• Japan announces it will freeze assets of 8 Russian officials, ban all exports to 71 Russian organizations, and ban exports of “cutting edge goods” to Russia.
• New Zealand announces financial sanctions against 8 Russian individuals and entities involved in disinformation campaigns and cyber attacks on Ukraine.
• The US temporarily suspends its import tariffs imposed by the Trump administration under Section 232–the “national security tariffs”–on Ukrainian steel for one year.
• The UK imposes new import tariffs on £1.4 billion worth of goods–including platinum and palladium–and new export bans covering £250 million worth of goods such as chemicals, plastics, rubber, and machinery.
• Following the G7 announcement, the US Treasury and State Departments announce new sanctions, including a ban on exports of accounting, trust, and corporate formation, and management consulting services. The US also imposes financial sanctions and visa restrictions on Russian bank executives and other individuals, defense companies, and state-owned television stations.
• To commemorate the end of the Second World War in Europe, G7 leaders state forthcoming sanctions will include phasing out dependence on Russian energy; export bans on key services; additional sanctions against Russian banks, oligarchs, and individuals; and efforts to fight off Russia’s propaganda.
• Canada sanctions additional Russian individuals and companies.
• The UK announces financial sanctions on Evraz plc, a Russian steel manufacturing and mining company.
• The UK announces a ban on services exports to Russia, including management consulting, accounting and public relations.It also freezes the assets of and imposes travel bans on 63 individuals and entities associated with the “Kremlin’s shadowy troll factory tactics.”
• Australia imposes financial sanctions and travel bans on 110 individuals, including Ukrainian separatists and members of Russia’s parliament.
• Canada sanctions additional Russian individuals and amends language in sanctions regulations.

• The UK announces financial sanctions on Evraz plc, a Russian steel manufacturing and mining company.
• The UK announces a ban on services exports to Russia, including management consulting, accounting and public relations.It also freezes the assets of and imposes travel bans on 63 individuals and entities associated with the “Kremlin’s shadowy troll factory tactics.”
• Australia imposes financial sanctions and travel bans on 110 individuals, including Ukrainian separatists and members of Russia’s parliament.
• New Zealand imposes financial sanctions and travel bans on Russian politicians and sanctions 6 companies in the Russian defense industry.

April 2022

• Switzerland implements most of the remaining EU sanctions in the package announced on April 8.
• Russian energy company Gazprom cuts off natural gas exports to Poland and Bulgaria over their refusal to pay in rubles.
• China cuts its applied MFN tariffs on coal imports to zero from 3-6 percent in a controversial move anticipated to disproportionately benefit Russian exports displaced from other markets.
• The UK announces it will cut tariffs to zero on all imports from Ukraine. It also plans to ban exports of certain products and technology to Russia, such as interception and monitoring equipment.
• The US prohibits Russian-affiliated vessels from entering US ports.
• The EU freezes assets and bans travel for two separatists involved in Russia’s annexation of Crimea and destabilization of eastern Ukraine.
• The UK bans imports of additional Russian goods, including silver, wood products, and caviar, and imposes an additional 35 percent import tariff on other imports from Russia and Belarus, including diamonds and rubber. The UK also imposes financial sanctions and travel bans on a number of Russian military commanders and others supporting Putin’s war.
• Newly re-elected President Aleksandar Vucic states that Serbia, a candidate for EU membership, will not impose sanctions on Russia because “we don’t believe sanctions change anything. You can pressure and force Serbia but this is our genuine opinion.”
• The Russian Foreign Ministry blacklists 29 Americans, including Vice President Kamala Harris and Meta CEO Mark Zuckerberg.
• Australia imposes sanctions on Putin’s and Lavrov’s daughters as well as more Russian politicians.
• The US Treasury sanctions entities and individuals involved in attempts to evade US sanctions. They include Transkapitalbank, Bitriver, and other companies in Russia’s virtual currency mining industry, and a network led by Russian oligarch Konstantin Malofeyev. The US State Department also announces visa restrictions on hundreds of individuals.
• In another action following the March 11 joint announcement, Japan passes a law withdrawing MFN tariff treatment for imports from Russia, which will raise import tariffs for certain products.
• Canada sanctions Russian Central Bank Governor Elvira Nabiullina, Putin’s daughters, and other Russians.
• The UK’s tax authority announces it will revoke the Moscow Stock Exchange’s status as a recognized stock exchange, depriving future investors of access to certain UK tax benefits.
• New Zealand sanctions 18 Russian banks and financial institutions, including the Central Bank of Russia, Sberbank, Alfa-Bank, and more.
• The UK sanctions additional Russian oligarchs, and its Parliament passes legislation banning imports of Russian iron and steel and exports to Russia of quantum technologies and advanced materials.
• The European Council introduces exceptions to some EU sanctions to mitigate the humanitarian crisis caused by Russia’s invasion of Ukraine.
• The UK imposes financial sanctions on 206 individuals, including 178 separatists of the so-called Donetsk and Luhansk People’s Republics, six Russian oligarchs, as well their close associates and employees.
• Switzerland sanctions Russia and Belarus by adopting the EU’s fifth round of sanctions announced on April 8, as well as issuing other amendments. Switzerland claims its list of sanctions “now fully mirrors that of the EU.”
• Australia imposes sanctions on 14 additional Russian state-owned enterprises.
• Adhering to the April 6 joint announcement, Japan bans imports of certain Russian products, prohibits new foreign direct investment in Russia, and imposes financial sanctions on 398 Russian individuals (including Putin’s daughters) and 28 Russian entities (including Sberbank and Alfa-Bank).
• US Department of Commerce expands the license requirements on export controls applied to Russia and Belarus to all items on the Commerce Control List (CCL).
• Canada imposes financial sanctions on an additional 33 entities in Russia’s defense sector.
• US Department of Commerce adds Iceland, Liechtenstein, Norway, and Switzerland to the list of countries excluded from the license requirements under its Russia/Belarus Sanctions rules (imposed on February 24 and March 2), including the Foreign Direct Product Rule. They join EU member states, Japan, South Korea, Canada, Australia, UK, and New Zealand.
• Biden administration signs two bills into law. The “Ending Importation of Russian Oil Act” (H.R. 6968) prohibits energy imports from Russia, and the “Suspending Normal Trade Relations with Russia and Belarus Act” (H.R. 7108) raises US tariffs toward each country to their rates in column 2 of the Harmonized Tariff Schedule.
• The UK announces financial sanctions targeting the daughters of Putin and Lavrov.
• Adhering to the April 6 joint announcement, the EU imposes its fifth major package of sanctions. It bans imports of Russian coal starting in August 2022 and other products such as wood, cement, fertilizers, seafood, and liquor. It expands export bans to include jet fuel, quantum computers, semiconductors, and other technology products and services. It prohibits Russian vessels from accessing EU ports as well as Russian and Belarusian vehicles from using EU roads. It imposes a full transactions ban on 4 more Russian banks and imposes financial sanctions on Russian oligarchs, politicians, and their family members, including Putin’s daughters. It also bans Russian companies from EU public procurement projects.
• The US Treasury sanctions Alrosa, Russia’s largest diamond mining company. The US State Department sanctions United Shipbuilding Corporation, a major Russian company responsible for building Russian navy warships.
• In its first enforcement action, the US Department of Commerce issues temporary denial orders (TDOs) revoking export privileges of 3 Russian airlines–Aeroflot, Azur Air, and UTair–for alleged violations of earlier US export controls.
• In response to revelations of Russian atrocities in Bucha, Australia imposes financial sanctions and travel bans on more Russian oligarchs.
• Following the G7 and EU announcement, the Biden administration issues an Executive Order (EO 14071) banning new outbound US foreign investment into Russia as well as services exports. The US Treasury also imposes financial sanctions on Sberbank, Alfa-Bank, and family members of Putin, Lavrov, and Russian Security Council members.
• Following the G7 and EU announcement, the UK imposes financial sanctions on Sberbank, Credit Bank of Moscow, and 8 oligarchs. The UK also bans all new outward investment to Russia, bans imports of Russian iron and steel products, commits to end imports of Russian coal and oil by the end of 2022 and gas “as soon as possible thereafter,” and bans exports to Russia of quantum and advanced material technologies.
• In response to revelations of Russian atrocities in the city of Bucha in Ukraine, the G7 and EU announce plans to document and share information about the atrocities and to impose more economic costs on Russia, including through additional sanctions. Early the next day, their foreign ministers issue a joint statement condemning the atrocities and welcoming investigations into Russia’s potential war crimes and crimes against humanity.
• New Zealand will apply a 35 percent tariff on all imports from Russia and extend its export ban to new products such as ICT equipment and engines.
• Canada prohibits exports of insurance services for the Russian aircraft, aviation, and aerospace industry and sanctions additional Russian oligarchs.
• US Treasury sanctions two Russian entities: Hydra, the world’s largest darknet market, and Garantex, a ransomware-enabling virtual currency exchange.
• New Zealand imposes sanctions on 36 Russian oligarchs and their family members.
• Australia bans exports of certain luxury goods to Russia.
• The US Department of Commerce expands export controls by adding to the Entity List 120 Russian and Belarusian firms alleged to support the two countries’ militaries.

March 31^st

• Australia announces it will withdraw MFN tariff treatment and apply an additional tariff of 35 percent to all imports from Russia and Belarus starting April 25.
• The UK sanctions Russian individuals and state media “who spread lies and deceit about Putin’s illegal invasion of Ukraine.”
• US Treasury expands financial sanctions on 21 entities and 13 individuals to prevent Russia from evading earlier sanctions and acquiring foreign technology. Treasury also expands sanctions under EO 14024 to include aerospace, marine, and electronics sectors.
• Putin signs a decree forcing gas payments to be made in rubles if buyers are from “unfriendly” countries, including western Europe.

March 30^th

• The UK Parliament passes legislation to prohibit maintenance on aircraft or ships belonging to specific sanctioned Russian oligarchs or their businesses and immediately uses the new laws to sanction two additional individuals. The legislation also extends earlier finance, trade, and shipping sanctions imposed on Crimea to Donetsk and Luhansk.

March 29^th

• Japan revises the list of luxury goods for which it originally banned exports to Russia on March 25.

March 28^th

• For the purposes of General Licence INT/2022/1438977 the DP is Russian Railways. The Joint Venture is GEFCO, a Joint Venture owned by Russian Railways and Stellantis, GEFCO S.A Rue Jean Jaures, 20-22, 92800 Puteaux, France.
  
• A Subsidiary is any entity owned or controlled by the DP, including:
  – GEFCO UK Ltd
  – GEFCO Forwarding UK
  – Auto XP Limited
  – XP Tech Limited

March 25^th

• The Federal Council implemented further goods and financial sanctions against Russia.

March 24^th 

• Group of 7 (G7) and EU leaders meet at NATO headquarters in Brussels and commit to fully implement sanctions already announced, work with other governments to impose similar sanctions, and prevent “evasion, circumvention and backfilling” that would undercut the effectiveness of already imposed sanctions. Leaders announce a joint initiative to respond “to evasive measures, including regarding gold transactions by the Central Bank of Russia.”
• UK announces new sanctions targeting Russian defense and other strategic industries, additional Russian banks, and individual businesspeople.
• Froze more than $6 billion worth of sanctioned Russian assets
• Following the G7 announcement, the US Treasury sanctions dozens of Russian defense companies, 328 members of the Russian Duma, and other Russian individuals. It also clarifies that existing US sanctions cover any transactions involving gold and the Central Bank of Russia.

March 19^th 

• Australia banned exports of alumina to Russia, which is needed to produce aluminum.

March 18^th 

• Japan added sanctions against 15 Russian individuals and 9 Entities
• Switzerland sanctions Russia by adopting the EU sanctions announced on March 15, including financial sanctions on 197 individuals and 9 entities, and an export ban on luxury goods. Switzerland will first do its own analysis before deciding whether to withdraw MFN import tariff treatment toward Russia.
• In an enforcement warning, the US publicly identifies dozens of commercial and private flights from third countries to Russia since March 2 that it claims were in violation of new US export controls on Russia or Belarus.
• Australian Government placed sanctions on 11 additional Russian banks and government entities

March 17^th

• Australia announces sanctions against Russian individuals, banks, and government entities.
• The UK suspends exchange of tax information with Russia and Belarus.

March 15^th

• The United Kingdom – The UK Government announced a ban on exports to Russia of high-end luxury goods, while also hitting hundreds of key products with new import tariffs. 9 entries have been added to the consolidated list and are now subject to a cyber sanctions asset freeze, 8 individuals and 1 Entity. Financial sanctions: Added, 377 Individuals; 10 Entities; & Amended 6 Entries.
• United States – SANCTIONS DESIGNATION: 11 Senior Russian Defense Officials; Office of Foreign Assets Control ADDED to Specially Designated Nationals List [SDN List]: 10 Individuals to RUSSIA-EO14024; 1 Individual to BELARUS; 4 Individuals to MAGNIT; 1 Entity to MAGNIT; Updated 1 records for Belarus; Updated 1 record for RUSSIA-EO14024
• European Union – Russia’s military aggression against Ukraine: Added 15 individuals and 9 Entities
• Canada – Special Economic Measures: 15 Russian Officials added

March 14^th

• Singapore – Added financial sanctions and restrictions on doing business in Russia.
• Australia – Designated Persons and Entities and Declared Persons—Russia and Ukraine – 33 Individuals added

March 11^th

• United States – Restrictions imposed that applies to luxury goods or any Russian or Belarusian oligarch or malign actor, regardless of location, who are designated on the Department of the Treasury, Office of Foreign Assets Control’s (OFAC) List of Specially Designated Nationals and Blocked Persons (SDN List) with any of the following designations: [RUSSIA-EO14024], [UKRAINE-EO13660], [UKRAINEEO13661], [UKRAINE-EO13662], [UKRAINE-EO13685], [BELARUS], and [BELARUSEO14038] or in situations in which any such Russian or Belarusian oligarch or malign actor is a party to the transaction as described in § 748.5(c) through (f). For purposes of this paragraph (a)(2), an ‘oligarch or malign actor’ is any natural person that is designated on the SDN List with any of the designations referenced in this paragraph (a)(2).
  • The President has signed a new Russia-related Executive Order Prohibiting Certain Imports, Exports, and New Investment with Respect to Continued Russian Federation Aggression.
  • RUSSIA-RELATED GENERAL LICENSE NO. 17
    RUSSIA-RELATED GENERAL LICENSE NO. 18
    RUSSIA-RELATED GENERAL LICENSE NO. 19
    UKRAINE-RELATED GENERAL LICENSE NO.23
  • Specially Designated Nationals List [SDN List] added 35 Individuals, 3 Entities, 1 Vessel, 1 Aircraft + 8 records amended (6 individuals & 2 Entities)
• The United Kingdom – 386 individuals have been added to the consolidated list. The 386 are members of the State Duma of the Russian Federation and are now subject to an asset freeze. The full list of names are located here. 15 entries have been amended on the consolidated list and remain subject to an asset freeze (10 individuals & 5 Entities).

March 10^th

• The United Kingdom – The following entries have been amended on the consolidated list and are still subject to an asset freeze:
  Celestino De Carvalho (Group ID: 12678)
  Antonio Injai (Group ID: 12664)
  Augusto Mario Co (Group ID: 12666)
  Daba Naualna (Group ID: 12669)
  Mamadu Ture (Group ID: 12665)
  Roman Arkadyevich Abramovich (Group ID: 14212)
  Igor Ivanovich Sechin (Group ID: 14213)
  Oleg Vladimirovich Deripaska (Group ID: 14214)
  Dmitri Alekseevich Lebedev (Group ID: 14215)
  Alexei Borisovich Miller (Group ID: 14216)
  Andrei Leonidovich Kostin (Group ID: 14217)
  Nikolai Petrovich Tokarev (Group ID: 14218)

• General Licence INT/2022/1327076 pertains to the continuing operation of Chelsea Football Club

March 8^th

• Australia – Department of Foreign Affairs and Trade [DFAT] and the Australian Sanctions Office [ASO]– Updated the consolidated list, Autonomous Sanctions (Designated Persons and Entities and Declared Persons – Russia and Ukraine) Amendment (No.4 and 5) Instrument 2022, which adds sanctions against Individuals and entities in the Russia/Ukraine situation.
• United States – Office of Foreign Assets Control [OFAC] – Issued a new Executive Order Prohibiting Certain Imports and New Investments With Respect To Continued Russian Federation Efforts To Undermine the Sovereignty and Territorial Integrity of Ukraine.

March 7^th

• Canada announced they are adding 10 new Russian individuals to its sanctions list who are “complicit” in the Russian invasion of Ukraine. Which includes former and current senior government officials, oligarchs, and supporters of the Russian leadership
• New Zealand published a travel ban list of over 100 individuals associated with the Russian invasion of Ukraine (Source Information attached)
• New Zealand announced that it will introduce legislation to allow it to bring first-of-its-kind sanctions against Russia following its invasion of Ukraine. The sanctions will give the country the ability to freeze Russian assets in New Zealand, prevent people and companies from moving their money and assets here to escape sanctions imposed by other countries, and stop superyachts, ships, and aircraft from entering the country’s waters or airspace. New Zealand has previously only been able to implement sanctions when the United Nations Security Council has imposed them. The Security Council will not be able to impose sanctions against Russia as Russia has the power to veto them. The Russia Sanctions Bill will pass under urgency this week, to provide further, extensive sanctions on Russia in response to the invasion of Ukraine.
• Japan is in discussions with the US and European countries about possibly banning Russian oil imports
• South Korea has decided to sever transactions with Russia’s central bank
• OFAC added a terrorist entity
• The sanction database SESAM (SECO Sanctions Management), which is decisive for Switzerland, adapted the measures against Myanmar. The change took effect today, March 7^th at 6 pm.

March 6^th

• The US government is consulting with its European allies on a potential import ban of oil from Russia.
• American Express suspended operations in Russia and Belarus
• Netflix halts service in Russia

March 5^th

• The EU has joined members of the Council of the Baltic Sea States (CBSS) in suspending Russia and Belarus from the Council’s activities. This decision is a part of the European Union’s and like-minded partners’ response to Russia’s invasion of Ukraine and the involvement of Belarus in this unprovoked and unjustified aggression.
• Mastercard and Visa suspended operations in Russia

March 4^th

• The United States Bureau of Industry and Security (BIS) added 91 entries to the Entity List
• Federal Department of Economic Affairs, Education and Research EAER amended the list of persons, companies, and organizations sanctioned on measures against Myanmar. The change is directly applicable in Switzerland.
• Russia enacts law punishing spread of “false information” about its “special military operation” in Ukraine, blocking access to Facebook and other news outlets. BBC, New York Times, and others suspend Russian operations in response.
• Switzerland adopts the EU sanctions on Russia announced on February 28 involving export controls on dual use items; prohibition of exports to Russia’s oil, aviation, and space industries; sanctions on the Russian Central Bank and other financial institutions; removal of Russian banks from SWIFT; and sanctions on numerous Russian individuals.

— Original Post — 3-1-22
Vital4 closely watches all developments in the world of compliance and sanctions. The recent invasion of Ukraine, started by Russia last week, has led to extensive sanctions on Russian businesses and oligarchs. These rapid changes are both expected and atypical in the sanctions world. Though we expect sanctions to take effect quickly and be strict, both the extent of these sanctions and Russia’s position as a major player in global trade make these sanctions particularly unique. To stay abreast of the fast-paced sanctions changes during the current conflict, Vital4 is automatically monitoring primary sanctions hourly to ensure we are capturing the most up-to-date data. Vital4 has also implemented an additional auditing process, to monitor against announced sanctions reports continuously throughout the day.

Our primary mission as a business is to deliver the best, curated datasets for screening and compliance, using Artificial Intelligence and Machine Learning to deliver the most accurate results.  We continue to enhance our systems and practices to make sure our partners always have the best data for their services and products.

United States Sanctions on Russia

On Wednesday, February 24th President Biden, according to the Wall Street Journal, vowed to make Vladimir Putin “an international pariah.” This vow taken and measures taken by the Office of Foreign Assets Control (OFAC) says the new sanctions will target 80% of Russia’s financial assets.

The new measures announced include:

Russia’s two largest financial institutions, Public Joint Stock Company Sberbank of Russia (Sberbank) and VTB Bank Public Joint Stock Company (VTB Bank), will no longer be able to process payments through the US financial system. Sberbank will have correspondent and payable-through account sanctions imposed on it. Blocking sanctions have also been imposed on three Russian financial institutions – Otkritie, Novikom, and Sovcom.

Debt and equity prohibitions against major state-owned and private entities

OFAC has expanded debt and equity restrictions to Russia’s economy. 13 major firms are covered by the directive, including six of Russia’s largest financial institutions.

General licenses 

OFAC has issued multiple general licenses to limit unintended consequences on third parties. The licenses authorize specific transactions related to international organizations, the COVID-19 pandemic, emergency flights, energy, and derivative contracts.

New actions targeting Russian elites

A number of “elites close to Putin” are also being hit with new sanctions. OFAC believes many of these individuals “participate in, or benefit from, the Russian regime’s kleptocracy.”

These individuals include:

Sergei Borisovich Ivanov; Nikolai Platonovich Patrushev; Igor Ivanovich Sechin; Senior executives at state-owned banks, including high-ranking executives at VTB Bank.

Canadian Sanctions on Russia

Canada has announced two tranches of sanctions against Russia, including:

• Financial restrictions on 31 individuals and 27 banks, all connected to Russia’s elite;
• The halting of all export permits, designed to curb exports worth $750 million across key sectors including aerospace, IT, and mineral shipments

United Kingdom Sanctions on Russia

According to Prime minister Boris Johnson, the UK will impose its “largest-ever” set of economic sanctions on Russia. British officials have compiled a “hit list” of oligarchs who will face these sanctions with the full list still to be announced.

So far those confirmed to be facing sanctions include:

Kirill Shamalov; Denis Bortnikov; Yury Slyusar; Gennady Timchenko; Igor Rotenberg; Russian President Vladimir Putin; Foreign Minister Sergeĭ Viktorovich Lavrov

Five Russian banks, including:

Rossiya; The Black Sea Bank; The General Bank; Promsvyazbank; IS Bank

More recently on Monday, February 28th, Chancellor Rishi Sunak announced the UK would join the European Central Bank and Federal Reserve in sanctioning Russia’s central bank.

Sanctions on Belarus:

‘The Foreign Secretary launched the first tranche of sanctions against Belarusian individuals and organizations in response to Belarus’ role in Russia’s invasion of Ukraine.”

Four senior defense officials and 2 military enterprises have been sanctioned with immediate effect under the UK’s Russia sanctions regime.

Those sanctioned include the Belarus Chief of the General Staff and First Deputy Minister of Defense, Major General Victor Gulevich; Major General Andrei Burdyko, Deputy Minister of Defense for Logistics and Chief of Logistics of the Belarusian Armed Forces;

Deputy Minister of Defence for Armament and Chief of Armament of the Belarusian Armed Forces, Major General Sergei Simonenko; Deputy Minister of Defence, Major General Andrey Zhuk.

Also sanctioned are state enterprises JSC 558 Aircraft Repair Plant and JSC Integral, a military semi-conductor manufacturer. JSC 558 provides maintenance and service to military aircraft at Baranovichi airbase, from which Russian aircraft operated as part of the invasion.

Individuals will be unable to travel to the UK and any UK-based assets will be frozen.

European Union Sanctions on Russia

Newly implemented EU sanctions are targeting the strategic sectors of the Russian economy by blocking their access to technologies and markets that are key for Russia.

Specific measures announced include:

• Sanctions against 351 members of the Russian State Duma
• Sanctions against 27 individuals and entities who have “contributed to the undermining or threatening of the territorial integrity, sovereignty, and independence of Ukraine”
• Limits on the ability of the Russian state and government to access EU capital and financial markets

The EU has also furthered its sanctions targeting Russia’s financial, energy and transportation sectors including export controls, financing, and visa restrictions, and confirmed it would freeze the assets of President Putin and Foreign Minister Lavrov, widen their sanctions targeting Belarus, ban all Russian aircraft from EU airspace, and authorize measures to target the Russia Today and Sputnik media outlets.

1) How could Russia’s war on Ukraine impact companies in the US?

It seems certain there will be many sanctions and exclusions implemented against Russia quickly. As in the past, with other countries that have received sanctions from the US and NATO, there is a lot of immediate pressure on countries within the alliance to omit Russian entities from their fiscal relationships. Businesses will have an added responsibility to ensure that all sanctions against Russia are swiftly adhered to.

2) How does the increase in post-pandemic fraud attempts impact this situation?

The pandemic and the economic downturn that accompanied it expanded opportunities for bad actors to identify new and strategic methods of committing fraud against entities and individuals. This uptake in fraudulent activity incentivizes government officials to take action to help remedy what has become an enormous issue. As the legislation imposed becomes more strict, the requirements for global businesses to adopt more stringent internal controls to combat fraud and corruption increase. During times of increased conflict, it is especially important to mitigate the risk of fraud, corruption, and terrorism when screening a business or individual up or down the supply chain or before hiring.

3) The economy seems to be getting worse and worse! How will this affect risk?

No doubt, the prices for most essentials have gone up and it does not seem like we are in for relief any time soon! When you couple the current state of the economy with “The Great Resignation”, where 4.3 million workers voluntarily quit their jobs in August of 2021, there is a distinct need to fill all of those abandoned roles. As businesses are desperately trying to rehire their workforce, supply-chain stress coupled with conflict breeds an environment ripe for corruption, fraud, and other abuses. Now more than ever, risk-management task forces and executives need to revisit and evaluate risk mitigation strategies, look for vulnerabilities, and take a clear-eyed view of potential outcomes for the business if the risk turns into reality.