On 29 November 2014, the European Union (EU) published measures targeting additional individuals and organisations to be added to the scope of EU sanctions measures against Russia. These measures widen the EU sanctions in respect of the current situation in Ukraine, originally imposed on 17 March 2014.

On 29 November, Council Implementing Regulation (EU) No 1270/2014 (“the Amending Regulation”) was published in the Official Journal of the European Union (O.J. 29.11.2014 L344/5) by the Council of the European Union.

The Amending Regulation amended Annex I to Council Regulation 269/2014, with immediate effect. The new measures target 13 individuals and 5 organisations said to be Ukrainian separatists involved in the disputed elections in eastern Ukraine, “in view of the continued gravity of the situation on the ground in Ukraine”. These persons are now subject the EU asset freezing restrictions and travel ban. The new EU measures mean that there are now 132 people and 28 entities on the EU’s Russia sanctions list.

Key compliance considerations

Any company subject to the scope of EU sanctions must:

• Check whether they hold any accounts, funds or economic resources for any of the individuals or entities targeted by the EU's sanctions and, where necessary, freeze such accounts, funds or economic resources.
• Consider their wider relationships and the risk of engaging with any entity owned or controlled by an EU sanctions target or any person acting on behalf of an EU sanctions target. 
• Suspend any type of dealing with accounts, funds or economic resources owned, held or controlled by EU sanctions targets or making accounts, funds or wider assets available to such persons - unless licensed by a relevant EU competent authority. 
• Report any findings with regards to funds or assets held on behalf of EU sanctions to relevant competent authorities with any additional information that would facilitate compliance with Regulation 269/2014.

Failure to comply with EU sanctions legislation or to seek to circumvent its provisions is a criminal offence.