European Union Imposes Further Sanctions and Export Controls on Russia, Expands Sanctions on Belarus

On March 9, 2022, the European Union imposed new sanctions on Russian oligarchs, businesspeople and government officials; significantly expanded sanctions on Belarus; and imposed new maritime-related export controls on Russia.

Below is a summary of the new measures.

New Asset Freeze Sanctions
The EU imposed asset freezes on following 14 Russian oligarchs and prominent businesspeople:
  • Dmitry Alexandrovich Pumpyansky, Chairman of the Board of Directors for Pipe Metallurgical Company, Galina Evgenyevna Pumpyanskaya, Chairwoman of the Board of trustees of BF “Sinara”, and Alexander Dmitrievich Pumpyansky, son of Dmitry Alexandrovich Pumpyansky and President of Group Sinara
  • Alexander Semenovich Vinokurov, businessperson with business interests in retail, pharmaceuticals, agriculture, and infrastructure, including leadership positions in Maraton Group and Magnit;
  • Andrey Igorevich Melnichenko, owner of EuroChem Group and SUEK, and Nikita Dmitrievich Mazepin, the son of Dmitry Arkadievich Mazepin, General Director of JSC UCC Uralchem;
  • Dmitry Arkadievich Mazepin, CEO of Uralchem Group;
  • Mikhail Eduardovich Oseevsky, President of PJSC Rostelecom;
  • Mikhail Igorevich Poluboyarinov, CEO of OJSC Aeroflot;
  • Sergey Alexandrovich Kulikov, Chairman RUSNANO LLC, Member of the Board of Directors of Rusnano JSC, first deputy Chairman of the board of the Military Industrial Commission;
  • Vadim Nikolaevich Moshkovich, Russian entrepreneur with business interests in agriculture and real-estate development, founder of Rusagro Group;
  • Vladimir Sergeevich Kiriyenko, CEO of VK Company Limited;
  • Andrey Andreevich Guryev, Member of the Board, the CEO and the Chairman of the Management Board of PJSC PhosAgro; and
  • Dmitry Vladimirovich Konov, Chairman of the Management Board of PJSC SIBUR Holding.
Moreover, the EU froze the assets of 146 members of the Russian Federation Council who ratified the decision to recognize the separatist regions of the Donetsk People's Republic and the Luhansk People's Republic as independent from Ukraine.

The new rules prohibit all movements, transfers, alterations, use of, access to, or dealings with such funds and economic resources, and the direct or indirect sharing of funds or economic resources with listed parties and entities subject to their ownership or control.

Maritime Export Controls on Russia
The EU imposed new export controls that restrict the export of listed maritime navigation goods and radio communication technology to Russia, including vessels, marine systems or equipment, and specially designed components for enumerated navigation and radio-communication equipment. Subject to limited exceptions, the controls prohibit sales and transfers of listed items to Russian entities, for end use in Russia, or for placement on board Russian-flagged vessels. The provision of associated technical, brokering, or other services, as well as financing or financial assistance is also prohibited.

The EU also added the Russian Maritime Register of Shipping to the list of state-owned enterprises subject to financing limitations. These maritime export controls are the latest in multiple rounds of export control restrictions imposed by the EU and G7 countries over the last ten days.

Expansion of Sanctions on Belarus
Finally, the EU expanded sanctions on Belarus yesterday, subjecting that country to the type of sanctions measures that have been imposed on Russia in recent weeks. The measures most notably:
  • Prohibit transactions with the Central Bank of Belarus related to the management of reserves or assets;
  • Prohibit the provision of public financing for trade and investment with Belarus, subject to limited exceptions;
  • Prohibit the listing of Belarusian entities with over 50% public ownership on EU trading venues, including the provision of services in relation to transferable securities, as of April 12, 2022;
  • Prohibit the acceptance of deposits from Belarusian nationals and residents where the total value of deposits of the national per credit institution exceeds €100,000, unless necessary for non-prohibited cross-border trade between the EU and Belarus;
  • Prohibit, with exception, selling euro-denominated transferable securities issued after April 12, 2022;
  • Prohibit, with exception, selling, supplying, transferring, or exporting euro-denominated bank notes to Belarus or Belarusians, including the Government and Central Bank of Belarus;
  • Prohibit, as of March 20, 2022, the provision of specialized financial messaging services, including SWIFT services, to Belagroprombank, Bank Dabrabyt, and the Development Bank of the Republic of Belarus, as well as their Belarusian subsidiaries whose proprietary rights are 50 % or more owned by the same.
Companies with operations subject to EU Member State jurisdiction should carefully review these new provisions and the associated exceptions.