Today, the U.S. Treasury, State, and Commerce Departments announced new sanctions and export control restrictions on Russia and Belarus, targeting parties in and activities related to the technology, quantum computing, finance, and advanced manufacturing sectors.  The Commerce Department’s Bureau of Industry and Security (BIS), in particular, expanded and updated a number of Russia- and Belarus-related sanctions measures under the Export Administration Regulations (EAR), including new controls on a number of common EAR99 items related to the chemicals, fluid handling, quantum computing, advanced manufacturing, and other industries.

Technology & Quantum Computing Sanctions

The Treasury Department’s Office of Foreign Assets Control (OFAC) added a number of Russian technology, space, and electronics companies and technical institutes to its List of Specially Designated Nationals (SDNs), including Limited Liability Company Group of Companies Akvarius (Akvarius), a large Russian electronics manufacturer.  Transactions ordinarily incident and necessary to the wind down of pre-existing dealings with Akvarius are authorized pursuant to a new General License No. 51 until October 15, 2022, but transactions involving the other new SDNs are now prohibited absent a specific license from OFAC.

In addition to the new designations, OFAC issued a ban on the export, reexport, sale, or supply of quantum computing services to any person in Russia pursuant to a new Determination under E.O. 14071.  OFAC considers prohibited quantum computing services to be any of the following when related to quantum computing, quantum computers, electronic assemblies thereof, or cryogenic refrigeration systems related to quantum computing:

“[I]nfrastructure, web hosting, or data processing services; custom computer programming services; computer systems integration design services; computer systems and data processing facilities management services; computing infrastructure, data processing services, web hosting services, and related services; repairing computer, computer peripherals, or communication equipment; other computer-related services; as well as services related to the exportation, reexportation, sale, or supply, directly or indirectly, of quantum computing, quantum computers, electronic assemblies thereof, or cryogenic refrigeration systems related to quantum computing[.]”

The ban excludes services provided to certain U.S.-owned or controlled entities located in Russia, as well as services provided in connection with the wind down or divestiture of entities located in Russia that are not owned or controlled by a Russian person.

The quantum computing services ban becomes effective on October 15, 2022.  In addition to the ban on quantum-related services, OFAC issued a separate Determination under E.O. 14024 allowing the agency to designate as an SDN any party it identifies as operating or having operated in Russia’s quantum computing sector, effectively immediately.

Banks That Join Russia’s MIR National Payment System Risk U.S. Sanctions

OFAC issued guidance today warning that non-U.S. banks could be added to the U.S. SDN List if they enter into new or expanded agreements involving the use of the MIR National Payment System outside of Russia.  Recent media reports have suggested that banks in Turkey may be particularly at risk of U.S. sanctions for their involvement in expanding the use of the payment system in Turkey, but financial institutions in central Asia and other regions also face risks if they are involved in expanding the use of MIR outside of Russia.

Expanded Export Controls

BIS made a number of important updates to its Russia- and Belarus-related export controls.  These include, among other things, the following changes:

  • Expansion to Belarus: The amendment expands the EAR’s “Russian Industry Sector Sanctions” to also generally apply to exports, reexports, and transfers to Belarus.
  • EAR99 fluid handling equipment, chemicals, and biologics:  The new rules prohibit the export, report, and transfer of a number of common EAR99 items that could be used for chemical or biological weapons production to Russia or Belarus without a license from BIS.  The newly controlled items, which are described in a new Supp. No. 6 to Part 746, include very common fluid handling equipment used in a range of industrial applications, such as reaction vessels, fermenters, agitators, heat exchangers, condensers, pumps (including single seal pumps), valves, storage tanks, containers, receivers, and distillation or absorption columns regardless of materials of construction.  Other controlled EAR99 items include certain biologics, chemicals, laboratory equipment.
  • Quantum computing & advanced manufacturing:  The amendment imposes a license requirement on the provision of certain EAR99 quantum computers and associated assemblies, components, and additive manufacturing equipment and related items to Russia and Belarus without a license from the Commerce Department.  EAR99 technology related to the production, development, and use of these items is also now controlled.
  • Expansion of Supp. No. 4 controls on EAR99 industrial items:  Today’s amendment adds 57 EAR99 industrial items to Supp. No. 4, including certain heat pumps, fork-lift trucks, sawing and cutting machines, and locomotives, among others, barring their sale to Russia without prior approval.  In addition, Supp. No. 4 is being expanded to apply to all items modified or designed as components, parts, accessories, or attachments of items listed in the supplement, even if those constituent items are not specifically included in the supplement, subject to certain exceptions.
  • Military and military-intelligence end users: The Commerce Department amended the EAR to allow the agency to designate end-users outside of Russia, Belarus, or other countries listed in sections 744.21 and 744.22 of the EAR as military end users (MEU) or military-intelligence end users.   While the MEU List is normally not exhaustive, the new rule limits application of military and military-intelligence related licensing requirements with respect to users outside of Russia and Belarus to those specifically identified on BIS’s Entity List.  The limitation reflects BIS’s understanding of the substantial compliance burden that would be imposed on exporters, reexporters, and transferors of having to independently identify the presence of Russian or Belarusian MEU or military-intelligence end users on a worldwide basis.
  • Dollar-value thresholds for luxury goods:  To better align U.S. controls with those implemented by allies, the new rule implements dollar value thresholds for controls related to exports, reexports, or transfers of certain luxury goods to Russia.  Previously, the restrictions generally applied regardless of the value of the goods at issue.

In addition to these updates, the amendment makes a number of corrections and clarifications to the EAR, including to license exceptions related to consumer communications devices and the news media, exceptions related to certain transfers of 5A992 and 5D992 items involving U.S.- or allied country-based companies, recordkeeping requirements, certain licensing policies, the General Prohibitions, the Commerce Country Groups, and the application of the Foreign Direct Product Rule.

Please contact our sanctions and export team with any questions regarding these developments.

In a rule change that was effective April 8, 2022, but communicated on April 11, 2022 the Commerce Department’s Bureau of Industry and Security (BIS) expanded coverage of export controls on Russia and Belarus to include any item with an Export Control Classification Number (ECCN).  Prior controls applied to items in Commerce Control List (CCL) Categories 3–9, but this rule expands export controls to cover Categories 0 (miscellaneous), 1 (materials), and 2 (materials processing) as well.  The expansion comes with corresponding revisions to BIS’s Russia- and Belarus-related foreign direct product rule (Russia/Belarus FDP rule).

Under the final rule, U.S. persons are broadly prohibited from exporting, reexporting, or transferring to Russia or Belarus not only U.S. goods, software, and technology listed on Categories 0 through 9 of the CCL, but also foreign-produced items that are derived from the same.   Newly controlled items include the following:

  • Certain composite materials;
  • Certain medical and biological products;
  • Pumps, valves, machine tools; and
  • All other controlled items, including materials and materials processing equipment, software, and technology.

This action marks a substantial expansion of BIS’s regulatory reach.  First, all items with an ECCN, i.e., those that are not designated as EAR99, are now subject to BIS’s Russia- and Belarus- related export controls.

Second, items made entirely outside the United States that are produced using U.S.-origin software or technology included in an ECCN, or made using a variety of commodities covered by ECCNs, require U.S. export licenses to be shipped from foreign destinations to Russia or Belarus under the expanded Russia/Belarus FDP rule.   As a result, non-U.S. sales involving the shipment of goods made outside the United States to Russia or Belarus may be subject to restrictions where U.S. know-how or products were involved in the non-U.S. manufacturing process.  The Russia/Belarus FDP rules are complex and far reaching–we have not described them in full here.

Third, the final rule expanded existing limitations on the availability of License Exception AVS to include aircraft registered in, owned or controlled by, or under charter or lease by Belarus or a national of Belarus, as opposed to only Russian aircraft.

All covered transactions will be subject to U.S. export license requirements.  With limited exception, BIS will review license applications involving items covered by the rules described above under a policy of denial.

Please contact our sanctions and export control team with questions about ensuring compliance with BIS’s latest export controls.

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.

 

Today, the European Union imposed sweeping export controls and sanctions on Belarus.  The export restrictions follows a similar template to the recent ban imposed against Russia.  Namely, the EU measure prohibits trade in listed dual-use goods and technology and broadly prohibits  trade of items that may contribute to Belarus’s military and technological enhancement.

The measure also prohibits the import or purchase of certain products from Belarus, including specified:

  • Wood products
  • Cement products
  • Iron products
  • Steel products
  • Rubber products, and
  • Machinery

The trade prohibitions come with accompanying restrictions on the provision of related services, and exceptions and derogations apply.

Last Friday, the European Union adopted its sixth round of sanctions against Russia, including the highly anticipated ban on imports of Russian seaborne crude oil and petroleum products and the provision of related services, subject to certain exceptions.

The European Union’s latest package also expands its ban on the provision of SWIFT interbank messaging network services, expands the EU dual-use export ban, prohibits the broadcasting or advertising of content from certain Russian media outlets to the European Union, prohibits the provision of various consulting services to Russia, and expands EU asset freeze restrictions.

EU Energy Ban

The latest EU sanctions package prohibits those subject to EU jurisdiction from directly or indirectly purchasing, importing, or transferring listed crude oil or petroleum products originating in, or exported from, Russia, subject to the exceptions below.  Notably, the EU ban currently does not apply to imports by pipeline of CN 2709 00 crude oil into Member States.  The direct or indirect provision by EU persons of related services, such as insurance, technical assistance, brokering services, or financing or financial assistance, is also prohibited.

The list of products subject to the EU Energy Ban are set out in Annex XXV to Regulation (EU) No 833/2014, as amended.  Specifically, the Annex describes the following two categories of energy products subject to the EU embargo, which are further defined by reference to the EU’s Combined Nomenclature (CN):

  • CN Code 2709 00, Petroleum oils and oils obtained from bituminous minerals, crude; and
  • CN Code 2710 00, Petroleum oils and oils obtained from bituminous minerals, other than crude; preparations not elsewhere specified or included, containing by weight 70 % or more of petroleum oils or of oils obtained from bituminous minerals, these oils being the basic constituents of the preparations; waste oils.

EU Energy Ban Exceptions

The EU Energy Ban takes immediate effect, but features transitory periods for preexisting contracts and other exceptions.  For contracts concluded before June 4, 2022, EU persons may continue conducting the following transactions, provided that the relevant Member State satisfies EU notification requirements:

  • EU persons may continue conducting limited transactions for near-term delivery of energy products falling under CN 2709 00 until December 5, 2022; and
  • EU persons may continue conducting limited transactions for near-term delivery of energy products falling under CN 2710 00 until February 5, 2023.

Temporary derogations allowing the importation of seaborne crude oil are also available to landlocked Member States whose supply of crude oil by pipeline is interrupted for reasons outside of the Member State’s control.

Nor does the ban apply to listed seaborne crude oil and energy products originating from third countries that are only being loaded in, departing from, or transiting through Russia, provided that the origin and owner of the products are non-Russian.

The EU measure contains specific derogations for the Czech Republic, Bulgaria, and Croatia.

Further Restrictions

The latest measures imposed a number of further restrictions.

First, the EU also imposed SWIFT-related restrictions on Sberbank, Credit Bank of Moscow, JSC Russian Agricultural Bank, and Belinvestbank (Belarusian Bank for Development and Reconstruction).  Persons subject to EU jurisdiction shall be prohibited from providing specialized financial messaging services to Sberbank, Credit Bank of Moscow, and JSC Russian Agricultural Bank, and Belinvestbank, including to entities whose proprietary rights are directly or indirectly owned, 50 % or more, by the same.

Second, the EU expanded its dual-use ban to capture additional exports that may enhance Russia and Belarus’s military and technological capabilities.  The measures include the addition of 80 chemicals to its list of goods subject to export requirements.  Alongside the expanded list of goods and technology are significant additions to the list of Russia and Belarus entities subject to EU dual-use restrictions.

Third, the measure prohibits those subject to EU jurisdiction from advertising products or services in any content produced or broadcast by designated individuals or entities, including the following:

  • Rossiya RTR / RTR Planeta;
  • Rossiya 24 / Russia 24; and
  • TV Centre International.

Fourth, similar to a recent move by the United States, the EU imposed a ban on the direct or indirect provision of various services, such as accounting, auditing, bookkeeping or tax consulting services, or business management consulting or public relations services to the Government of Russia or Russian entities.  The service ban includes various exceptions to its prohibitions.

Fifth, the EU is now requiring that Member States impose appropriate criminal penalties for sanctions violations.  Member States are also required to provide appropriate measures of confiscation of proceeds derived from EU regulation infringements.

Finally, the EU added 65 individuals and 18 entities to its asset-freeze.  The designations focus on Russian military and defense targets, and proliferators of disinformation.  As a reminder, all funds and economic resources belonging to, owned, held, or controlled by designated individuals or entities shall be frozen, and no funds or economic resources shall be made available, directly or indirectly, for the benefit of such individuals or entities.

 

On Friday, the Commerce Department’s Bureau of Industry and Security (BIS) added 120 parties operating in the Russian and Belarusian aerospace, maritime, and defense sectors to the Entity List.  BIS designated the parties for attempting to procure items subject to the Export Administration Regulations (EAR) for the Russian and Belarusian militaries and for their military modernization efforts in Russia.  The addition of the parties to the Entity List means that no goods, software, or technology (technical knowhow) subject to the EAR may be exported, reexported, or transferred to the designated entities without a license from BIS, which is very unlikely to be granted.  The restrictions apply to all items on the EAR’s Commerce Control List (CCL), as well as less sensitive EAR99 items.

BIS designated 95 of the parties as “military end users” under Footnote 3 of the Entity List, subjecting the entities to the expansive Russian/Belarusian Military End User foreign-direct product rules (MEU FDPRs).  The MEU FDPRs extend the jurisdictional reach of the EAR to control items that are the direct product of any software or technology subject to the EAR that is on the CCL or that are produced by certain plants or major components of plants that are themselves the direct product of any U.S.-origin software or technology on the CCL.  Exports, reexports, and transfers of such items are prohibited without a license if an entity with a footnote 3 designation is a party to the transaction, or if there is knowledge that the item will be incorporated into or used in the production or development of any part, component, or equipment produced, purchased, or ordered by a footnote 3 entity.

The designations are effective Friday, April 1, 2022, with expected publication of the Final Rule on April 7, 2022.

Today, the United Kingdom expanded sanctions on Russia by imposing asset freeze restrictions on 59 Russian and six Belarusian actors.  The measures target key strategic industries in Russia, and include large banks, defense companies, and Russian elites.

Of note, the following Russian banks and companies have been added to the U.K.’s consolidated asset freeze list:

  • Alfa-Bank JSC
  • Gazprombank
  • Russian Agricultural Bank
  • Alrosa
  • Kronshtadt
  • Wagner
  • Russian Railways
  • Russian Venture Company

Moreover, the United Kingdom imposed asset freeze and travel sanctions on many Russian elites and oligarchs, including:

  • Oleg Tinkov, founder of Tinkoff Bank;
  • Herman Gref, CEO of Sberbank;
  • Oleg E Aksyutin, Deputry Chairman of Gazprom PJSC;
  • Didier Casimiro, the First Vice President of Rosneft;
  • Zeljko Runje, Deputy Chairman and First Vice President for Oil, Gas, and Offshore Business Development of Rosneft;
  • Galina Danilchenko, named mayor of Melitopol;
  • Eugene Markovich Shvidler, a billionaire oligarch.

With respect to Belarus, the United Kingdom sanctioned the following entities:

  • Bank Dabrabyt Joint Stock Company
  • CJSC Belbizneslizing
  • Industrial-Commercial Private Unitary Enterprise Minotor-Service
  • JSC Transaviaexport Airlines
  • Limited Liability Company Belinvest-Engineering
  • OJSC KB Radar-Managing Company Holding Radar System

All accounts, and other funds or economic resources, and any funds owned or controlled by designated individuals and entities in the UK must be frozen and UK persons must refrain from dealing with frozen funds or assets unless authorized.  As with U.S. blocking restrictions, reporting and anti-circumvention requirements apply.

The UK issued two general licenses (INT/2022/1424276 and INT/2022/1424277) authorizing the wind down of certain transactions involving Alfa Bank JSC,  GazPromBank,  Rosselkhozbank,  SMP Bank,  Ural Bank for Reconstruction and Development, and Bank Dabrabyt Joint Stock Company through April 23, 2022.

The UK also clarified that existing general license INT/2022/1381276 authorizes the provision of financial services to wind down certain transactions entered into prior to March 1, 2022 with entities owned, controlled, or acting on behalf of Russia’s Central Bank, National Wealth Fund, or Russian Ministry of Finance.

 

March 4, 2022 Update: This post was updated after BIS published new export controls on oil and gas equipment and Entity List sanctions on firms related to the Russian defense industry.

Today, the United States announced another round of significant sanctions and export control restrictions on Russia and Belarus in response to the deteriorating situation in Ukraine.  Today’s actions subject Belarus to the same harsh export control restrictions that were imposed on Russia last week and effectively close U.S. airspace to Russian aircraft.  The White House also announced that United States would impose new restrictions on exports of oil and gas equipment to Russia and blocking sanctions on Russian defense companies.  We expect the Commerce and Treasury Departments to implement those restrictions in the coming days.

U.S. Belarus Export Controls

In coordination with the European Union, the U.S. Commerce Department announced amendments to the Export Administration Regulations today that subject Belarus to the same sweeping export control restrictions as those imposed on Russia last week.

The new rules effectively prohibit the export, re-export, or transfer of a broad range of dual-use items to Belarus, including all items listed in Categories 3 through 9 of the Commerce Control List, the U.S. dual use control list.  With limited exception, the U.S. government will review license applications related to these exports subject to a presumption of denial, which means that licenses will rarely be granted.  The rules also impose broad restrictions on exports of items to Military End Users and Uses in Belarus and added add two Belarusian entities to the Entity List as “military end users,” broadly prohibiting the transfer of items subject to the EAR to the listed parties.

Today’s amendments also extend the “Foreign Direct Product Rule” (FDPR) to apply exports to Belarus and Belarusian Military End Users, expanding the scope of items manufactured outside the United States that are now subject to U.S. export control and licensing requirements.

Additional information on the nature of these expanded controls is available in our prior post on Russia, available here.

Oil & Gas Equipment Restrictions

The White House announced that the United States would adopt new export controls on oil and gas extraction equipment shipped to Russia.  The new controls are designed to limit the ability of Russia to support its refining capacity over the long term.  Additional information about the oil and gas export controls is available here.  The EU also recently imposed similar restrictions on an array of items used for oil refining.

Defense Sanctions

The White House also announced that 22 Russian defense-related entities would be added the List of Specially Designated Nationals (SDN List), including companies that manufacture “combat aircraft, infantry fighting vehicles, electronic warfare systems, missiles, and unmanned aerial vehicles for Russia’s military.”  As of this writing, the SDN List had not yet been updated with these entities.

On March 4, 2022, BIS added 91 entries to its Entity List, effectively prohibiting exports of items “subject to the EAR” to the listed parties.  The entities, which are located in Belize, Russia, Singapore, and the United Kingdom, were sanctioned for their involvement or support of Russian security, military, and defense efforts.

Airspace Restrictions

In coordination with U.S. allies, the United States also announced the closure of U.S. airspace to Russian aircraft.  The new measures ban aircraft certified, operated, registered or controlled by any person connected with Russia from the United States.  Accordingly, the Department of Transportation issued a notice today revoking Russian passenger and cargo airlines’ ability to operate to and from U.S. destinations and refusing entry of Russian-operated aircraft into U.S. airspace.

Yesterday, the United Kingdom expanded export controls on shipments to Russia and imposed new sanctions on Russian and Belarusian parties in response to the ongoing conflict in Ukraine.  The latest measures impose a dual-use trading ban on Russia, asset freezes on specified parties, and financial sanctions on Sberbank.

Dual Use Export Controls

The UK updated its dual use export control regulations to remove Russia as a permitted destination from open general export licenses, including licenses involving the export of chemicals, cryptographic development, and oil and gas exploration.  The UK has also suspended approval of new export licenses for exports of dual-use items to Russia.  The moves align the UK’s approach with the broad dual use export control restrictions imposed by the United States, EU, and other allies in recent days.

Sanctions: Asset Freezes & Financial Restrictions

Matching sanctions imposed by other countries, the UK imposed asset freeze restrictions on the Russian Direct Investment Fund, its CEO, Kirill Alexandrovich Dmitriev, VEB.RF, Bank Otkritie, and Sovcombank in Russia.  The UK also imposed sanctions on JSC 558 Aircraft Repair Plant and JSC Integral in Belarus and four Belarusian individuals.  All accounts, and other funds or economic resources, and any funds owned or controlled by designated individuals and entities in the UK must be frozen and UK persons must refrain from dealing with frozen funds or assets unless authorized.  As with U.S. blocking restrictions, reporting and anti-circumvention requirements apply.

The UK also imposed financial and investment restrictions on PJSC Sberbank limiting, among other things, the ability of UK credit or financial institutions to process sterling payments involving Sberbank.

The latest UK sanctions can be found here, here, here, and here.

Today, the European Union announced that it would close EU airspace to all Russian-owned, Russian registered, or Russian-controlled aircraft, including private aircraft owned by the Russian elite.  The bloc’s move follows similar measures adopted by a growing number of Member States in recent days.

The EU will also impose sanctions on Russia Today and Sputnik, two Russian government media outlets, limiting those companies’ ability to operate in Europe.

In the same announcement, the EU indicated that it will impose sanctions on critical sectors of the Belarusian economy.  The measures include sanctions designed to “stop [Belarusian] exports of products from mineral fuels to tobacco, wood and timber, cement, iron and steel,” according to a statement released by European Commission President Ursula von der Leyen.