The EU, US and UK have imposed sanctions against Russia in the context of ever-growing tensions at the border with Ukraine, Russia having decided to recognise independent entities and send Russian troops to certain areas of Ukraine’s Donetsk and Luhansk.
On 21 February 2022 President Biden issued an Executive Order on Blocking Property of Certain Persons and Prohibiting Certain Transactions With Respect to Continued Russian Efforts to Undermine the Sovereignty and Territorial Integrity of Ukraine. The Executive Order is a response to Russia’s recognition of two separatist regions in Ukraine as independent states and sending Russian troops there. The following is prohibited by the Executive Order:
- New investment in the so-called Donetsk People’s Republic (DNR) region, Luhansk People’s Republic (LNR) region or other regions of Ukraine (‘’Covered Regions’’) decided by the US Secretaries of State and Treasury by a US person, wherever located;
- The importation into the US, directly or indirectly, of any goods, services, or technology from the Covered Regions;
- The exportation, reexportation, sale, or supply, directly or indirectly, from the US, or by a US person, wherever located, of any goods, services, or technology to the Covered Regions;
- Any approval, financing, facilitation, or guarantee by a US person, wherever located, of a transaction by a foreign person where the transaction by that foreign person would be covered by these prohibitions if performed by a US person or within the US.
Also, all property and related interests that are in the US, come within the US or are in the possession or control of US persons of the following persons are blocked:
- Those who operate or have operated since the date of the order in the Covered Regions;
- To be or have been since the date of the order a leader, official, senior executive officer, or member of the board of directors of an entity operating in the Covered Regions;
- To be owned or controlled by, or to have acted or purported to act for or on behalf of, directly or indirectly, any person whose property and interests in property are blocked pursuant to this order;
- Or to have materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, any person whose property and interests in property are blocked pursuant to this order.
However, the White House stated that the Department of the Treasury will issue six general licenses to minimize the unintended negative impact of the new sanctions against the Ukrainian government and inhabitants, which will allow for:
- A short-term wind down of activities, export of food, medicine, and medical devices, personal remittances;
- Telecommunications, internet and mail services;
- Aid by international organizations.
Presidents of the European Council and European Commission also responded, announcing a first package of sanctions to be formally tabled, and targeting:
- Those involved in the illegal decision;
- Banks that are financing Russian military and other operations in those territories;
- The ability of the Russian state and government to access the EU’s capital and financial markets and services, to limit the financing of escalatory and aggressive policies;
- Trade from the two breakaway regions to and from the EU, to ensure that those responsible clearly feel the economic consequences of their illegal and aggressive actions.
The EU stated being ready to adopt additional measures at a later stage if needed. Further, on 21 February 2022 , the EU Council decided to impose restrictive measures on an additional 5 individuals for actively supporting actions and implementing policies that undermine or threaten the territorial integrity, sovereignty and independence of Ukraine. EU Representative for Foreign Affairs and Security Policy, stated that Belarus would face the same sanctions as Moscow should there be an invasion of Ukraine from its territory.
The UK Foreign Commonwealth and Development Office has today updated the UK Sanctions List, providing for 8 additional listings, subjecting the individuals and entities to an asset freeze.