The Week in Review delivers information and analysis on recent developments related to sanctions against Russia and key implications for the public, private, and non-profit sectors as the United States (U.S.), the European Union (EU), and the United Kingdom (UK) continue to lead a global sanctions campaign that has been unprecedented in its speed, complexity, and impact in responding to Russia’s ongoing war against Ukraine.
DOLFIN users can visit the updated Russia Sanctions page on DOLFIN to find additional resources and information on sanctions against Russia, including sanctions evasion typologies, case studies, and analysis on other sanctions programs implicating Russian actors, such the Global Magnitsky Sanctions Program Targeting Human Rights Violations and Corruption.
Recent Developments Related to Sanctions Against Russia
Since the last update on 21 July, a number of sanctions-related actions took place and are detailed below. These actions include the U.S. Treasury’s designation of additional individuals and entities under its Russia sanctions program; the European Union’s adoption of its seventh round of sanctions targeting Russia; and the UK government announcing prohibitions against the provision of professional services to Russia.
U.S. actions include:
EU-related actions include:
UK actions include:
Key Implications (Public, Private, and Non-Profit Sectors)
The ongoing designations of individuals and entities in or otherwise related to Russia continues to increase the risk of engaging in prohibited activity. Additional sanctions targeting parties acting on behalf of sanctioned targets or otherwise engaging in sanctions evasion should be anticipated. Understanding red flags associated with sanctions evasion continues to be a key tool to ensuring compliance.
Actions like the ban on professional services implemented by the UK and the ban on gold exports implemented by the UK and EU demonstrate that there continues to be coordination among the U.S., EU, and UK regarding Russia sanctions. However, financial institutions and those engaged in global commerce should pay attention to the variations in the scope and timing of the prohibitions in order to ensure compliance with all applicable regimes. Screening lists should be updated in a timely manner to ensure the prompt restriction of assets or other activity to the ever-increasing body of targets related to Russia.
The ban on professional services in the UK is a major change for parties subject to the UK’s sanctions jurisdiction, and many firms that provide accounting, business and management consulting, and public relations services are expected to be impacted by the new prohibitions. Parties who provide such services should evaluate their potential exposure to ensure that they are not serving clients in Russia knowingly or inadvertently in breach of the new regulations.
1 Treasury Targets the Kremlin’s Continued Malign Political Influence Operations in the U.S. and Globally (29 July 2022), https://home.treasury.gov/news/press-releases/jy0899.
2 Russian National Charged with Conspiring to Have U.S. Citizens Act as Illegal Agents of the Russian Government (29 July 2022), https://www.justice.gov/opa/pr/russian-national-charged-conspiring-have-us-citizens-act-illegal-agents-russian-government.
3 Russia: EU Renews Economic Sanctions Over Russia’s Military Aggression against Ukraine for Further Six Months (26 July 2022), https://www.consilium.europa.eu/en/press/press-releases/2022/07/26/russia-eu-renews-economic-sanctions-over-russia-s-military-aggression-against-ukraine-for-further-six-months/.
4 Russia’s Aggression Against Ukraine: The EU Targets Additional 54 Individuals and 10 Entities (22 July 2022), https://www.consilium.europa.eu/en/press/press-releases/2022/07/22/russia-s-aggression-against-ukraine-the-eu-targets-additional-54-individuals-and-10-entities/.
5 Russia’s Aggression Against Ukraine: EU Adopts “Maintenance and Alignment” Package (21 July 2022), https://www.consilium.europa.eu/en/press/press-releases/2022/07/21/russia-s-aggression-against-ukraine-eu-adopts-maintenance-and-alignment-package/.
6 UK Sanctions Russian Gold Exports (26 June 2022), https://www.gov.uk/government/news/uk-sanctions-russian-gold-exports.
7 UK Sanctions Russian Officials Propping Up Putin’s Proxy Administrations in Ukraine (26 July 2022), https://www.gov.uk/government/news/uk-sanctions-russian-officials-propping-up-putins-proxy-administrations-in-ukraine.
8 The Russia (Sanctions) (EU Exit) (Amendment) (No. 14) Regulations 2022 (21 July 2022), https://www.legislation.gov.uk/uksi/2022/850/made.