Russia/Ukraine Sanctions Update - Month Of December - Export Controls & Trade & Investment Sanctions

I. U.S. Sanctions

U.S. President Biden Issues New Executive Order to Strengthen the U.S. Department of the Treasury's Tools to Disrupt and Degrade Russia's War Machine: On December 22, 2023, President Biden issued a new Executive Order (E.O.) amending E.O. 14024 and E.O. 14068. This E.O. further targets Russian sanctions evasion and solidifies the U.S. commitment to the G7 Leaders' Statement, making clear to foreign financial institutions that facilitating significant transactions relating to Russia's military-industrial base may expose them to U.S. sanctions. The new amendment to E.O. 14024 authorizes the imposition of U.S. sanctions on foreign financial institutions that are either (1) facilitating significant transactions on behalf of persons designated for operating in certain key sectors of the Russian economy that support the country's military-industrial base; or (2) facilitating significant transactions or providing services involving Russia's military-industrial base, including those relating to specific manufacturing inputs and technological materials that Russia is seeking to obtain from foreign sources. This also authorizes Treasury to prohibit the importation of products that have been processed or substantially transformed in third countries, such as Russian seafood and diamond products. Read more>>
U.S. Department of the Treasury Tightens the Price Cap with New Sanctions and Updated Guidance: On December 20, 2023, the Department of the Treasury's Office of Foreign Assets Control (OFAC), in line with actions previously taken by partners in the Price Cap Coalition, added a Government of Russia-owned ship manager, as well as several obscure oil traders who have emerged as frequent participants in the seaborne transportation of Russian-origin oil, to its Specially Designated Nationals (SDN) list following the imposition of the price cap. OFAC also released General License No. 81, "Authorizing Limited Safety and Environmental Transactions Involving Certain Persons or Vessels Blocked on December 20, 2023" and General License No. 82, "Authorizing the Wind Down of Transactions Involving SUN Ship Management D Ltd." The Department of the Treasury also updated its Guidance on Implementation of the Price Cap Policy for Crude Oil and Petroleum Products of Russian Federation Origin, implementing changes to strengthen the attestation and recordkeeping processes for certain covered service providers.
U.S. Department of the Treasury Imposes Sanctions on More Than 150 Individuals and Entities Supplying Russia's Military-Industrial Base: On December 12, 2023, the Department of the Treasury implemented the commitments made by G7 Leaders and took action against third-country actors who materially support Russia's war by targeting Russian military procurement networks and those who help Russia acquire machine tools, equipment, and key inputs; and further curtailing Russia's use of the international financial system to further its war in Ukraine. The U.S. Department of State issued a corresponding fact sheet regarding the measures. Read more>>
U.S. Department of the Treasury Designates Two Members of Russian State Intelligence-Sponsored Advanced Persistent Threat Group: On December 7, 2023, OFAC, in coordination with the United Kingdom, added two individuals, associated with an advanced persistent threat group that is sponsored by the Russian Federal Security Service, to its SDN list, and has targeted individuals and entities in the United States, United Kingdom, and other allied and partner countries. The two individuals designated were Ruslan Aleksandrovich Peretyatko, an FSB officer, and Andrey Stanislavovich Korinets, an IT worker in Syktyvkar, Russia. Read more>>
U.S. Departments of the Treasury, Justice, and Commerce Target Russian Defense Procurement Network: On December 5, 2023, OFAC designated several individuals and entities to target a network involved in procuring electronics with military applications for Russia-end users and issued General License No. 10, "Authorizing the Wind Down of Transactions Involving Tabak Invest LLC." Concurrent with OFAC's action, the U.S. Department of Justice unsealed two indictments against the leader of the network, Hans De Geetere, related to his years-long scheme to unlawfully export sensitive, military-grade technology from the U.S. to end users located in the People's Republic of China and the Russian Federation. The Department of Commerce also concurrently added Hans De Geetere and five entities to the Bureau of Industry and Security Entity List. Read more>> Read more>> Read more>>
U.S. Department of the Treasury Targets Belarusian Revenue Generators for Lukashenka, Human Rights Abuses, and Cogs in Russia's War Machine: On December 5, 2023, OFAC added eleven entities and eight individuals to its SDN list to pressure Alyaksandr Lukashenka's authoritarian regime for its brutal suppression of Belarus's democratic civil society, corrupt financial enrichment of the Lukashenka family, and complicity in Russia's unjustified war against Ukraine. Read more>>
U.S. Department of the Treasury Imposes Additional Price Cap-Related Sanctions: On December 1, 2023, OFAC imposed sanctions on three entities and blocked three vessels that used Price Cap Coalition services while carrying Russian crude oil above the Coalition-agreed price cap. OFAC also issued General License No. 78, "Authorizing Limited Safety and Environmental Transactions Involving Certain Persons or Vessels Blocked on December 1, 2023." Read more>>
Owner of Kansas Company Pleads Guilty to Crimes Related to Scheme to Illegally Export U.S. Avionics Equipment to Russia and Russian End Users: On December 19, 2023, the Department of Justice released that the owner of a Kansas-based company plead guilty for his role in a years-long conspiracy to circumvent U.S. export laws by filing false export forms with the U.S. government and, after Russia's unprovoked invasion of Ukraine in February 2022, continuing to sell and export sophisticated and controlled avionics equipment to customers in Russia without the required licenses from the U.S. Department of Commerce. Read more>>
U.S. Department of the Treasury Releases Blog on How Sanctions and Export Controls are Limiting Putin's Capabilities: On December 14, 2023, the U.S. Treasury Department released a blog on the impacts of sanctions and export controls on the Russian economy. The blog, by Treasury's Chief Sanctions Economist, analyzes the consequences of the brutal war itself, U.S. and partners' sanctions and related measures, and the Russian government's policy response to those measures. Read more>>
Former Special Agent in Charge of the New York FBI Counterintelligence Division Sentenced to 50 Months for Conspiring to Violate U.S. Sanctions on Russia: On December 14, 2023, the Department of Justice released that a former Special Agent in Charge of the FBI Counterintelligence Division in New York was sentenced to 50 months in prison and ordered to pay a $40,000 fine for conspiring to violate the International Emergency Economic Powers Act and to commit money laundering in connection with his 2021 agreement to provide services to Oleg Deripaska, a sanctioned Russian oligarch. Read more>>
U.S. Departments of State and Justice Take Actions to Further Disrupt Russian Cyber Activities: On December 7, 2023, the Departments of State and Justice acted against cyber actors Callisto Group, Star Blizzard, and COLDRIVER, which are connected to Russian Federal Security Service Center 18, for long-running cyber espionage campaigns that targeted numerous U.S.-based entities and individuals. The Department of Justice unsealed an indictment charging Andrey Stanislavovich Korinets and Ruslan Aleksandrovich Peretyatko for their role in a criminal hacking conspiracy that targeted U.S.-based entities and individuals, including U.S. Department of Energy facilities' employees. The U.S. Department of State's Rewards for Justice program is offering a reward of up to $10 million for information leading to the identification or location of any person who, while acting at the direction or under the control of a foreign government, engages in certain malicious cyber activities against U.S. critical infrastructure, in violation of the Computer Fraud and Abuse Act. Read more>>
Department of State Announces Additional U.S. Security Assistance for Ukraine: On December 6, 2023, the Department of State announced a new package of weapons and equipment to support the people of Ukraine. The package provided up to $175 million of arms and equipment, including air defense munitions, additional ammunition for High Mobility Artillery Rockets Systems, artillery ammunition, High-speed Anti-Radiation Missiles, anti-armor missiles, small arms ammunition, demolitions munitions for obstacle clearing, equipment to protect critical national infrastructure, and spare parts, ancillary equipment, services, training, and transportation. Read more>>
U.S. Department of Justice Charges Four Russia-Affiliated Military Personnel Charged with War Crimes in Connection with Russia's Invasion of Ukraine: On December 6, 2023, the Department of Justice unsealed war crime charges against four Russia-affiliated military personnel. The charges include torture, inhumane treatment, and unlawful confinement of a U.S. national in Ukraine. Read more>>
U.S. Department of State Announces Reward Offer for Information Leading to the Arrest and/or Conviction of Russian National Accused of Sanctions Evasion: On December 5, 2023, the Department of State announced a reward offer under the Transnational Organized Crime Rewards Program of up to $7 million for information leading to the arrest and/or conviction of Russian national Artem Aleksandrovich Uss for his conspiracy to participate in or attempt to participate in transnational organized crime. Read more>>

II. EU Sanctions

EU Adopts 12th Sanctions Package Against Russia: On December 18, 2023, the EU adopted its 12th sanctions package against Russia. The new package introduces additional asset freeze measures, together with amendments to the EU asset freeze framework targeting Russia and introduces amendments to sectoral sanctions targeting Russia. Read more>> Read more>> Read more>> Read more>> Read more>> Read more>>
EU Imposes Sanctions in View of Iran's Military Support to Russia's War Against Ukraine: On December 11, 2023, the EU sanctioned 6 persons and 5 entities involved in Iran's development and production of unmanned aerial vehicles used in Russia's illegal war of aggression against Ukraine. Those targeted will be subject to an asset freeze and travel ban to the European Union. These are the first listings under the newly established framework for restrictive measures in view of Iran's military support of Russia's war against Ukraine. Read more>> Read more>>
EU Updates Guidance Note on the Implementation of Firewalls: On December 1, 2023, the EU published its updated Guidance Note detailing safeguards (firewalls) to prevent designated persons from executing certain rights connected to ownership or effective control over an EU entity. The EU considers that as a minimum standard, safeguards should be introduced for entities operating in sectors considered as "essential," including, but not limited to, the sectors of food production, pharmaceuticals, fertilizers, chemicals, water management and sanitation, nuclear power. Read more>>
EU Prolongs the EU Global Human Rights Sanctions Regime: On December 4, 2023, the EU prolonged the EU Global Human Rights Sanctions Regime for three years, until December 8, 2026. These sanctions target 67 natural and legal persons and 20 entities, including a considerable number from Russia, responsible for serious human rights violations and abuses worldwide. Read more>> Read more>>
EU's Council and Parliament Reach Political Agreement to Criminalize Violation of EU Sanctions: On December 12, 2023, the EU's Council and the European Parliament concluded their negotiations for an EU law which introduces criminal offences and penalties for the violation of EU sanctions. The new rules will include a list of criminal offences related to the violation and circumvention of EU sanctions, such as, for example, failing to freeze assets, breaching travel bans and arms embargoes, providing prohibited or restricted economic and financial services, transferring funds to a third party or providing false information to conceal funds that should be frozen. Read more>> Read more>>
EU's General Court Dismissed the Action Brought by Evgeny Borisovich Zubitskiy Against EU Sanctions: On December 6, 2023, the General Court dismissed the action brought by Evgeny Zubitskiy, co-owner, chairman of the Board and CEO of Industrial Metallurgical Holding, highlighting, amongst others, that the Council correctly established that Zubitskiy fulfilled the conditions of a leading businessperson. Read more>>
EU's General Court Dismissed the Action Brought by Roman Arkadyevich Abramovich Against EU Sanctions: On December 20, 2023, the General Court dismissed the action brought by Roman Abramovich, major shareholder of the steel group Evraz. The General Court considered that the Council did not err in its assessment by deciding to include, then maintain, Mr. Abramovich's name on the lists at issue, in the light of his role in the Evraz group and, in particular, its parent company. The General Court also rejected Mr. Abramovich's argument alleging disproportionate infringement of the freedom of movement as a Portuguese, and thus EU national. Read more>>
EU's General Court Ruled That EU Sanctions Do Not Prohibit a Russian Citizen Holding a Private License from Piloting a Plane in the EU: The applicant, a Russian and Luxembourg national who holds a Luxembourgish private pilot license and uses aeroplanes at Luxembourg Airport, brought an action challenging the prohibition applicable to all Russian-registered, and to any non-Russian-registered aeroplane which is owned, chartered or otherwise controlled by a Russian person, from landing in, taking off from, or overflying the territory of the EU. In its analysis, the General Court found that the prohibition at issue does not apply to the applicant and refers solely to the economic or financial control of an aeroplane and not the control exerted by the pilot. Read more>>
EU Responds to a Question on the 11th Sanctions Package Against Russia: On December 14, 2023, the EU explained that 87 new entities added through its 11th package of sanctions to the list of entities directly supporting Russia's military and industrial complex in its war against Ukraine, will be subject to tighter export restrictions for dual-use and advanced technology items. The EU further highlighted that an additional key element of the 11th package is the new anti-circumvention tool, which allows the EU to restrict the sale, supply, transfer or export of specified goods and technology to certain third countries which are considered to pose a continued and particularly high risk of circumvention. Read more>> Read more>>
EU Commission Responds to a Question on the Implementation of a Horizontal Sanctions Regime Against Russia: On December 20, 2023, the Commission reaffirmed that Member States are responsible for the implementation and enforcement of EU sanctions. The Commission monitors the uniform implementation by national competent authorities and dedicates resources to support them by providing information to stakeholders and by engaging in a dialogue to collect feedback on how the sanctions are implemented. In addition, the Commission is in regular contact with the Member States through the Commission's Expert Group on Sanctions Implementation, and with the industry, to explain the measures, discuss their impact, ensure compliance with EU sanctions and prevent that their misapplication indirectly supports the Russian war effort. Read more>> Read more>>
Russian Authorities Import Western Components via China and Hong Kong: Russian imports of microelectronics, wireless and satellite navigation systems and other critical parts subject to sanctions have recovered to near pre-war levels with a monthly run rate of $900 million in the first nine months of 2023. All of this indicates that, while Western sanctions imposed over Russia's full-scale invasion on Ukraine, had a temporary impact, Russia largely succeeded in reconfiguring supply chains, with the help of China, Hong Kong and countries in Russia's backyard like Kazakhstan and NATO member Turkey. Read more>>
Dutch Company Reportedly Found Sending Shipments to Russia in Breach of EU Sanctions: A Russian-owned Dutch company, ETW-Tekhnologiya, was found to organize shipments of technological components and other items to Russia over the past 18 months. Russian customs data show that ETW-Tekhnologiya sent eight shipments that included restricted electronics components that can be used in Russian weapons systems. Additionally, ETW-Tekhnologiya is reported to have sent another 135 shipments valued at over 1.2 million euros which were likely to violate sanctions. The company also sent thousands of other shipments of technological items not on sanctions lists since the Russian invasion of Ukraine. The goods were all seemingly sent to various destinations, ETW-Tekhnologiya made it appear as if shipments were to be delivered to clients located in Dubai or Hong Kong, but the customs data showed the products cleared customs inspections in Russia. Read more>>
Austria Backs EU Russia Sanctions After Ukraine Removes Raiffeisen from Blacklist: Austria has given its approval to a 12th package of EU sanctions on Russia after Ukraine removed Raiffeisen Bank International from a blacklist. Austria had been pushing to remove the bank from a Ukrainian list dubbed "international sponsors of war", which sets out to shame companies doing business in Russia and supporting the war effort by, for instance, paying taxes. The blacklist has no legal standing, but it is symbolically important, reinforcing public pressure on Raiffeisen to quit Russia, something the Austrian bank has said it is willing to do but which has yet to happen. Read more>>
EU Takes First Step to Raise Money for Ukraine from Russian Frozen Assets: On December 12, 2023, the European Commission presented a plan to funnel the proceeds from Russian assets frozen in the EU to help rebuild Ukraine. Russian foreign reserves were frozen by countries participating in sanctions at the onset of Russia's war on Ukraine and the majority sit in the EU. The Commission's proposal would target €180 billion worth of frozen assets that are with Belgium's Euroclear, a clearinghouse acting as a custodian for Russian reserves. Read more>>

III. UK Sanctions

OFSI extends general licence relating to Evraz plc's North American subsidiaries: On December 22, 2023, OFSI updated General Licence INT/2022/1710676 relating to the continuation of business of the North American subsidiaries of Evraz plc. Among other things, the general licence was extended to 30 September 2024. Read more>> Read more>>
OFSI updates financial sanctions guidance: On December 21, 2023, OFSI updated its guidance on financial sanctions, monetary penalties and enforcement of Russia sanctions. The latest version of OFSI's guidance is available at: https://www.gov.uk/government/publications/financial-sanctions-faqs.
OFSI updates guidance on reporting information to OFSI: On December 21, 2023, OFSI updated its guidance on reporting information to OFSI. The updates included adding a new DP Reporting Template (for UK and non-UK Persons respectively) and an Immobilised Assets Reporting Document. The guidance also explains to whom and how the relevant documents apply. Read more>>
OFSI publishes blog on correspondent banking restrictions: On December 21, 2023, OFSI published a blog post describing recent updates to the correspondent banking restrictions under UK sanctions. In the blog post, OFSI notes that it anticipates "most of the transactions affected by this measure will be transactions which have used correspondent banking earlier in the chain of transactions, and where the correspondent bank is designated for the purposes of regulation 17A." Read more>>
UK Government amends Russia sanctions list: On December 21, 2023, the UK Government made one variation to the entry for Yuri Alekseyevich Soloviev. The individual is subject to an asset freeze, trust services, and transport sanctions. Read more>>
OFSI updates Oil Price Cap Guidance: On December 20, 2023, the UK Government updated its guidance to the private sector on the Maritime Services Ban and Oil Price Cap. Among other things, the updated guidance provides additional clarity around the attestation requirements, reporting requirements for UK nationals in third countries and reporting timelines. The corresponding general licence has also been updated. Read more>> Read more>>
UK Government amends Russia sanctions list: On December 18, 2023, the UK Government amended the entry for Sergei Sergeevich Tregub, an individual that remains subject to an asset freeze, travel ban, trust services sanctions, and transport sanctions. The UK Government also made an administrative change to the entry for Alexander Borisovich Arutyunov, who remains subject to an asset freeze, travel ban, trust services sanctions. Read more>>
OFSI issues general licence for payments processing: On December 15, 2023, OFSI issued General Licence INT/2023/4078352 authorising the processing of payments by UK credit or financial credit institutions to or from certain designated Russian banks until 22 December 2023. Read more>>
UK Government adds Russian bank to UK sanctions list: On December 15, 2023, the UK Government added JSC Bank Novikombank to the UK sanctions list under the Russia regime. The UK Government also amended entries on the UK sanctions list for 27 other financial institutions, which each remain subject to an asset freeze, correspondence banking restrictions and trust services sanctions. Read more>>
UK Government introduces new trade and financial sanctions against Russia: On December 14, 2023, the UK Government introduced the Russia (Sanctions) (EU Exit) (Amendment) (No. 4) Regulations 2023 and the Russia (Sanctions) (EU Exit) (Amendment) (No. 5) Regulations 2023, which implement new trade and financial sanctions targeting Russia. The new legislation bans inter alia the export of certain goods carrying a risk of military or industrial usage, including machine parts and electronics, and the import of Russian metals and diamonds. Read more>> Read more>> Read more>>
UK Government issues new general trade licence for Russian iron and steel: On December 11, 2023, the UK Government issued Licence GBSAN0001, which permits the import (as well as related services) into the UK of goods that would otherwise be prohibited by the third country Russia-connected iron and steel ban in certain circumstances. Read more>>
UK announces new unit to clamp down on evasion of Russian sanctions: On December 11, 2023, UK Industry and Economic Security Minister, Nusrat Ghani, announced that the UK government will launch the Office of Trade Sanctions Implementation (OTSI) in early 2024. OTSI will be responsible for inter alia the civil enforcement of trade sanctions, investigating trade sanctions breaches, issuing penalties and referring cases to HMRC. Read more>> Read more>>
UK Government amends one entry on UK sanctions list under Russia regime: On December 11, 2023, the UK Government made an administrative amendment to the entry for OOO MVIZION under the Russia sanctions regime. The entity remains subject to an asset freeze and trust services sanctions. Read more>>
HMRC issues three compound settlements offers between August and November 2023: On December 1, 2023, HMRC announced it had issued compound settlement offers to three UK exporters totalling in excess of £77,000.00. These settlements relate to unlicensed exports of Dual Use goods and related activity controlled by The Export Control Order 2008 and a breach of The Russia (Sanctions) (EU Exit) Regulations 2019. Read more>>
UK Government amends Russia sanctions list: On November 30, 2023, the UK Government amended the sanction list under the Russia regime to update the entry for Mihajlo Perencevic. The individual remains subject to an asset freeze and trust services sanctions. Read more>>
OFSI successfully defends first court review: On November 28, 2023, OFSI published a blog on its successful defence of a legal challenge against its decision to refuse to grant certain licence requests to a UK assets freeze target. OFSI stated that it will "robustly defend baseless challenges against its decisions and ensure financial sanctions are implemented to support the objectives of the Russia sanctions regime and applicable licensing grounds". By way of background, on October 26, 2023, the High Court handed down its judgment rejecting a legal challenge by Mikhail Fridman against OFSI's decision to refuse him certain licence requests. Mr Fridman had argued that OFSI was wrong to refuse certain licence requests made under the prior obligations, basic needs and routine holding and maintenance licensing grounds in respect of his primary residence in the UK. However, Mr Justice Saini dismissed the claim on all grounds. Read more>>
UK Law Society updates guidance on sanctions and publishes guidance note on ownership and control: On November 27, 2023, the Law Society updated its guidance on the UK sanctions regime to say that it has published a joint note with the Bar Council on the "control" test following the NBT v Mints case. The guidance note was prepared prior to the High Court's judgment in Litasco SA v Der Mond Oil and Gas Africa SA. Read more>>

IV. Russia/Ukraine Sanctions

Ukraine Introduces New Sanctions against Legal Entities and Individuals: The Order of the President of Ukraine No. 813/2023 adds 185 individuals and 181 legal entities to the sanction lists. Read more>>
Ukraine Launches an Open Database of Foreign Components in Russian Weapons: Ukrainian National Anti-Corruption Agency launched an open database of foreign components found in Russian weapons since the start of the war against Ukraine. The database contains information relating to the type of weapon, manufacturer of the component, technical characteristics, etc. The database is available by the following link: https://sanctions.nazk.gov.ua/military-components/
Ukraine Suspends the Status of Raiffeisen Bank as an International Sponsor of War: Ukrainian National Anti-Corruption Agency temporarily suspended the status of Raiffeisen Bank International (RBI), an Austrian Bank, as an international sponsor of war. According to the statement of the Agency, the status was suspended upon bilateral consultations with the European Commission. In September, the Agency also suspended the status of the Hungarian OTP Bank and later excluded it from the list of the international sponsors of war following negotiations with Hungary. Read more>>
Russia considers further oil export cuts in December: On December 17, 2023, Russia threatened to deepen oil export cuts in December by potentially 50,000 barrels per day (bpd) or more, earlier than promised, as the world's biggest exporters try to support declining global oil prices. Read more>>
Russia and Iran Sign a Declaration on Counteracting the Sanctions: On December 5, 2023, Russia and Iran signed the Declaration on the Ways and Measures of Counteracting, Easement and Compensation of the Negative Consequences of Unilateral Compelling Measures. The Declaration states that unilateral sanctions, as well as court decisions based on such sanctions, are against the international law and shall not be recognized or enforced, while governmental or private property shall not be frozen. According to the Declaration, the states shall prepare a road map for decreasing dependence of international trade on national currencies and create regional financial institutions independent from the global ones. Read more>>
Russia Extends the Restrictions on Certain Financial Transactions: The Decrees of the President of Russia No. 958 extends the restrictions on payment for shares in non-resident legal entities for the Russian residents until the end of 2024. The restriction on the transactions with Russian securities for non-residents from "unfriendly" states was extended until the end of 2025. Besides, the order extends certain other restriction imposed by Russia to financial and corporate transactions. Read more>>
Russia Takes Control over the Shares of Wintershall and OMV in Russian Assets: Based on the Decrees of the President of Russia No. 965 and 966, German oil and gas company Wintershall and the Austrian OMV lost their rights in companies that were developing the Yuzhno-Russkoye oil and gas condensate field and the Achimov deposits of the Urengoy field. According to the decrees, all rights and obligations of joint ventures will be transferred to LLCs created by the Russian government. It is suggested that SOGAZ and Gas Technologies shall acquire the confiscated shares. Read more>>
Russia Takes Control over Pulkovo Airport from the Foreign Companies: Based on the Decree of the President of Russia No. 909 dated 30 November 2023, the Russian Government established a separate company to take control over the Saint-Petersburg Pulkovo airport from foreign shareholders. The director of the new company is appointed by the Government. The new company exercises full control over the votes in the managing company of the airport. Read more>>
Russia Talks about Retaliation is Response to Confiscation of the Russian Assets by the EU and US: The Russian Minister of Finance Anton Siluanov stated that Russia might confiscate the assets of foreign companies and citizens currently blocked in type C accounts if foreign governments move to confiscate the Russian frozen assets abroad. Besides, Russian Ministry of Foreign Affaires stated that confiscation of the Russian assets might trigger the breakdown of diplomatic relations with the United States. Read more>> Read more>>
The Russian Central Bank Established the Rules for the Transit Accounts of Financial Brokers: The new rules will regulate the status of the transit depository accounts for the non-resident owners of securities. The new rules follow the initiative of the Russian Government to exchange the securities of Russian residents blocked in foreign financial institutions to the assets of foreign corporations blocked by the Russian Government. The initiative, however, has not been mirrored by the relevant changes in the EU and US sanctions regimes. Read more>>

V. Other Notable Developments

Japan Expands Sanctions Over Russia's Ukraine Invasion: On December 15, 2023, Japan announced expanded sanctions over Moscow's invasion of Ukraine, revealing dozens of newly sanctioned firms and other organizations, including export bans against some outside Russia and Belarus. Tokyo added 57 organizations to its sanctions list in Russia and six others in countries including the United Arab Emirates, Armenia, Syria, and Uzbekistan. Read more>>
Canada Adds Thirty Individuals Who Are Subject to a Broad Dealings Ban: On December 8, 2023, Canada further amended the Special Economic Measures (Russia) Regulations to add 30 individuals who are subject to a broad dealings ban. They comprise 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. Read more>>
Australia Sanctions Thirteen Russians Over Kara-Murza Poisonings: On December 7, 2023, Australian Foreign Minister, Penny Wong, said in a statement that Canberra has imposed sanctions on three officers of Russia's Federal Security Service and ten other Russian citizens over two near-fatal poisonings of opposition politician, Vladimir Kara-Murza, in 2015 and 2017. Read more>>
Canada Prohibits the Direct Import of Diamond and Diamond-Related Products Originating from Russia: On December 5, 2023, Canada further amended the Special Economic Measures (Russia) Regulations to prohibit the direct import of diamond and diamond-related products originating from Russia, in-line with G7 commitments. These amendments ensure that revenues cannot be generated from Canada that could eventually support Russia's budget and ongoing violation of Ukraine's sovereignty and territorial integrity. The amendments also include necessary changes to the existing luxury export ban and import ban in the Russia Regulations to ensure consistency with the new additions to the import ban on diamond and diamond-related products. Read more>>
Switzerland Freezes $8.8 billion of Russian assets: On December 2, 2023, the Swiss Government claimed it froze an estimated 7.7 billion Swiss francs ($8.81 billion) in financial assets belonging to Russians. Read more>>

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