Since the publication of our 9 March 2022 consumer alert, the US, UK and EU and different allied nations have imposed further sanctions and export controls on key components of the Russian economic system. This consumer alert summarizes the UK and EU’s newest actions, which have been carefully coordinated.
UK Chancellor Rishi Sunak has urged companies “to think very carefully about their investments in Russia … there is no case for new investment in Russia.”
The European Commission’s President Ursula von der Leyen made clear that the EU would “continue to work in lockstep [with its allies] to ramp up the economic pressure against the Kremlin.”
On 11 March 2022, a variety of further measures had been introduced in a joint assertion by the leaders of the G-7. The majority of these are but to be applied, together with:
- additional debt and fairness restrictions focused at Russian entities which are straight or not directly supporting the warfare;
- restrictions on Russia acquiring financing from main multilateral monetary establishments, together with the International Monetary Fund, the World Bank or the European Bank for Reconstruction and Development;
- a crackdown on evasion and closure of loopholes in present sanctions, together with evasions by means of using digital/cryptoassets; and
- efforts to fight the Russian authorities’s makes an attempt to unfold disinformation.
On 17 March 2022, the Russian Elites, Proxies and Oligarchs Task Force (REPO Task Force), a worldwide activity pressure targeted on coordinated enforcement of sanctions and export management measures, held its first assembly. In a joint assertion revealed on the identical date, the REPO Task Force confirmed its dedication to prioritising its assets and working collectively to take all out there authorized steps to search out, restrain, freeze, seize, and, the place applicable, confiscate or forfeit the belongings of sanctioned people. The signatories to this assertion included officers from the US, the UK, Australia, Canada, Japan, France, Germany, Italy and the EU.
In current days, related authorities within the UK and EU issued essential steering on matters such because the aggregation of possession pursuits (as mentioned beneath), and we count on that authorities will proceed to difficulty additional steering and FAQ on sanctions matters.
Unless in any other case famous, this consumer alert describes developments by means of 20 March 2022. The panorama is quickly altering, and we are going to present extra data on new developments — together with bulletins of additional sanctions anticipated by the US, UK and EU on March 24, 2022 — in upcoming consumer alerts.
Unless in any other case famous, this consumer alert describes developments by means of 20 March 2022. The panorama is quickly altering, and we are going to present extra data on new developments in upcoming consumer alerts.
I. UK Sanctions and Export Controls
The UK has continued to undertake additional laws to implement its sanctions and export management measures.
The Economic Crime (Transparency and Enforcement) Act 2022
The Economic Crime (Transparency and Enforcement) Act 2022 (Economic Crime Act) obtained royal assent on 15 March 2022, following an expedited passage by means of Parliament. It launched a variety of provisions referring to financial crime and cash laundering, in addition to provisions related to sanctions.
The most vital provisions involving sanctions embrace:
- Urgent designation process: This permits an individual to be designated for sanctions regardless of the absence of cheap grounds to suspect that they’ve been concerned in sanctionable conduct. It applies the place (i) the individual is topic to comparable sanctions by the US, EU, Australia, Canada or every other specified nation and (ii) it’s within the public curiosity to make such a designation. Urgent process designations finish after 56 days, except by then the individual is licensed as an concerned individual. The pressing process got here into pressure on 15 March 2022 and has already been utilised by the UK to impose additional blocking sanctions.
- Strict legal responsibility regime: This will take away the requirement that an individual should have “known, suspected or believed” that they had been breaching sanctions prohibitions to be able to be topic to a dedication {that a} breach has occurred. This will not be but in pressure.
- Reporting on sanctions breaches: The Treasury might publish experiences the place no financial penalty has been imposed, as long as it’s happy (on a steadiness of chances) that an individual has breached a prohibition. This will not be but in pressure.
Asset Freezes
On 10 March 2022, the UK imposed blocking sanctions on seven enterprise house owners,1 and on 11 March 2022, it imposed them on 386 members of the State Duma of the Russian Federation who voted in favor of legal guidelines recognising the Donetsk and Luhansk areas as unbiased states.
Further blocking sanctions had been introduced on 15 March 2022 on 364 individuals, together with members of the Federation Council of the Russian Federation, senior political figures,2 a number of extra enterprise house owners3 and seven companies.4 Plenty of these sanctions had been imposed pursuant to the brand new pressing designation process.
Transport Restrictions
On 8 March 2022, the UK handed laws that strengthened the prevailing restrictions on Russian plane.5 This laws establishes powers to take away plane owned, operated or chartered by designated individuals from the UK register. In addition, the laws makes it a legal offence for any Russian plane6 to fly over or land within the UK.
The laws additionally extends the UK’s present restrictions in relation to Russian ships and, granting powers to detain Russian-registered ships in UK ports.
Russian Oil Restrictions
On 8 March 2022, the UK introduced its intention to progressively section out the import of Russian oil over the present yr. No sanctions laws referring to this has been revealed. The authorities additionally introduced the institution of a Taskforce on Oil to help firms to find various provides.
Additional Import Tariffs
A listing of Russian and Belarusian merchandise will face an extra 35% improve in import tariffs, the federal government introduced on 15 March 2022. Those embrace: wooden, paper, iron, metal, copper, equipment, cement, iron ores, fertilisers, cereals, drinks, spirits (together with vodka) and vinegar. We count on the laws referring to this to be handed this week.
Further Export Control Measures
Additional measures proscribing exports to Russia and Belarus had been introduced on 15 March 2022. In explicit, the UK will ban luxurious items exports to Russia, which is anticipated to have an effect on luxurious automobiles, high-end vogue and artworks. This will not be in pressure but. The UK additionally introduced its intention to disclaim Russia and Belarus entry to Most Favoured Nation tariff therapy in relation to a variety of key exports. The authorities additionally mentioned it’s going to not difficulty any new ensures, loans and insurance coverage for exports to Russia and Belarus.
Suspension of Tax Co-Operation
On 17 March 2022, the UK introduced that it was suspending the alternate and sharing of tax data with Russia and Belarus below the UK’s alternate of data agreements. This tax data is exchanged as a part of a worldwide collaboration to deal with tax compliance dangers.
General Licences
The UK’s sanctions regulator, the Office of Financial Sanctions Implementation (OFSI), has issued restricted exemptions to sure sanctions restrictions.
The following new normal licences have been issued:
- General Licence INT/2022/1327076: This permits Chelsea FC to make sure funds for the needs of its continued operation (together with the cost of worker wages) from 10 March 2022 till 31 May 2022, following the blocking sanctions imposed on its proprietor, Roman Abramovich.
- General Licence INT/2022/1381276: This permits individuals to supply monetary companies for the needs of winding down any derivatives, and repurchase and reverse-repurchase transactions entered into previous to 1 March 2022 with (i) the Russian Central Bank, (ii) the Russian National Wealth Fund, and (iii) the Russian Ministry of Finance. It is in pressure from 22 March 2022 till 2 May 2022.
In addition, OFSI has revealed amendments to 2 present normal licences:
- General Licence INT/2022/1272278: This licence, protecting individuals winding down transactions to which they’re a celebration associated to VTB Bank or its UK subsidiaries, prolonged from 25 February 2022 to 27 March 2022. It was amended on 7 March 2022 to increase the definition of subsidiaries to cowl any entity owned or managed by VTB Bank. In addition, OFSI (i) confirmed that the prevailing guidelines don’t require that funds payable to VTB in the midst of winding down transactions be paid right into a frozen account and (ii) urged that, if funds turn out to be payable to a subsidiary of VTB as a part of winding down transactions with these subsidiaries, consideration ought to be given to how the possession and management provisions in The Russia (Sanctions) (EU Exit) Regulations 2019 may apply to such funds.
- General Licence INT/2022/1277778: This licence, from 1 March 2022 till 31 March 2022, permits UK credit score or monetary establishments to (i) proceed a correspondent banking relationship with Sberbank and (ii) course of sterling cost to, from or by way of Sberbank or a non-UK or UK credit score or monetary establishment owned or managed straight or not directly by Sberbank. On 11 March 2022, OFSI amended the licence to make it clear that the authorizations granted in relation to each actions prolonged to conduct with a non-UK or UK credit score or monetary establishment owned or managed straight or not directly by Sberbank.
The Department for International Trade’s Export Control Joint Unit has additionally issued a General Trade Licence in relation to the restrictions on offering technical help, monetary companies and funds, and brokering companies referring to sure restricted items and expertise:
- General Trade Licence (Russia Sanctions, Vessels): This permits the supply of technical help, monetary companies and funds, and brokering companies referring to vessels, their part components and associated expertise the place (i) the vessel is transferring from a 3rd nation to Russia, or to the UK or a 3rd nation from Russia, or transiting Russian territorial waters, (ii) the vessel is transferring below its personal energy, and (iii) the motion of the vessel will not be for the aim of switch of possession of the vessel or any of its part components, or a change of the operator of the vessel, from 17 March 2022.
Insurance/Reinsurance
As famous in our 9 March 2022 consumer alert, on 8 March 2022, the UK handed laws that prohibits those that are topic to UK jurisdiction from offering insurance coverage or reinsurance companies referring to aviation or area items and expertise (i) to individuals related with Russia or (ii) to be used in Russia.
The Export Control Joint Unit issued a normal commerce licence particularly in relation to those new prohibitions:
- General Trade Licence (Russia Sanctions, Aviation Insurance): From 8 March 2022 till 28 March 2022, this permits the supply of:
- (i) insurance coverage companies referring to aviation or area items and expertise if, prior to eight March 2022, the insurance coverage supplier
- (a) didn’t reinsure any of their obligations; or
- (b) reinsured their obligations and that reinsurance cowl has not been rendered unenforceable, suspended, annoyed or prohibited by any relevant sanctions; and
- (ii) reinsurance companies referring to aviation or area items and expertise if the insurance coverage obligations they’re reinsuring haven’t been rendered unenforceable, suspended, annoyed or prohibited by any relevant sanctions.7
- (i) insurance coverage companies referring to aviation or area items and expertise if, prior to eight March 2022, the insurance coverage supplier
Guidance
OFSI revealed up to date steering on 4 March 2022 on the UK’s Russian sanctions framework summarising the monetary sanctions which have been imposed towards Russian entities and people, together with, inter alia, asset freezes and restrictions on dealing in transferable securities or granting new loans and credit score preparations, in addition to out there exceptions.
On 10 March 2022, OFSI revealed a weblog submit offering additional steering in relation to the brand new sanctions that made it clear that OFSI considers crypto belongings to be an financial useful resource, and encompassed by UK monetary sanctions laws.
An 11 March 2022 joint assertion from OFSI, the Financial Conduct Authority and the Bank of England reiterated that monetary companies companies working within the crypto asset sector should guarantee they’re in compliance with the UK’s sanctions. The assertion: (i) outlines a variety of sanctions-specific compliance measures that the federal government encourages crypto asset companies to think about and (ii) identifies red-flag indicators which will counsel an elevated danger of sanctions evasion.
Although OFSI has not but up to date its FAQs relating to Russian sanctions, it hosted a public webinar on 17 March 2022 to be able to handle sure questions on the brand new regime.
On 22 March 2022, OFSI revealed up to date steering on the UK’s monetary sanctions framework. In explicit, the up to date steering confirms that when making an evaluation on possession and management, OFSI won’t combination completely different designated individuals’ holdings in an organization except the shares or rights are topic to a joint association between the designated events, or one get together controls the rights of one other.
II. EU Sanctions and Export Controls
On 11 March 2022, shortly after the EU’s third set of measures towards Russia and its collaborators was finalised, the European Commission introduced that it might prolong the scope of restrictive measures on Russia and Belarus with a fourth sanctions package deal.
This was applied on 15 March 2022, and features a complete prohibition of any transactions with sure Russian state-owned firms, an export ban of European luxurious items to Russia, an import ban on Russian iron and metal, and a far-reaching ban on new investments within the Russian power sector.8 However, in contrast to the US, the EU didn’t impose an import ban on Russian oil and fuel.
In addition, on 11 March 2022, the EU issued additional amendments to different current sanctions, together with main additions to the EU Consolidated Sanctions List and complete sectoral sanctions towards Belarus due to its assist for Russia within the warfare in Ukraine.9
Expanded Export/Import Controls and Sectoral Sanctions
The EU expanded the scope of its Russia-related export and import restrictions by amending sectoral sanctions below Council Regulation No. 833/2014 (Amended Regulation 833).10
As of 16 March 2022, it’s prohibited to import iron and metal merchandise listed in Annex XVII to Amended Regulation 833, straight or not directly, that originated in or had been exported from Russia11 or to supply associated technical or monetary companies. Related contracts that had been concluded earlier than 16 March 2022 could also be executed till 17 June 2022. This additionally applies to any ancillary contracts which are vital for the execution of such contracts.
It can be now prohibited to export to Russia luxurious items listed in Annex XVIII to Amended Regulation 833 that originated within the EU if their worth exceeds €300 per merchandise (or different values specified within the annex).12 Listed items embrace caviar, truffles, alcoholic drinks, cigars, perfumes, leather-based items, garments, carpets, jewellery, watches, porcelain, artworks, digital objects for home use of a price exceeding €750 and automobiles of a price exceeding €50,000.
As of 10 March 2022 it’s also prohibited to export to Russia any maritime navigation items or expertise listed in Annex XVI to Amended Regulation 833, regardless whether or not or not these items originated within the EU, or to supply associated technical or monetary help.13
With this fourth set of measures towards Russia, the EU additionally comprehensively amended the listing of entities to which it’s prohibited to promote or export dual-use items (as listed in Annex I of Regulation (EU) 2021/821) or items which may contribute to Russia’s army and technological enhancement or the event of its protection and safety sectors (as listed in Annex VII to Amended Regulation 833). Such entities are listed in Annex IV to Amended Regulation 833.14
With respect to the power sector, the brand new sectoral sanctions embrace:
- funding restrictions.15 For instance, article 3a of Amended Regulation 833 prohibits (i) the acquisition of any new participation, or the extension of any present participation, in any Russian entity working within the power sector in Russia or (ii) granting any new mortgage or credit score to these entities. By derogation, the competent nationwide authorities might grant exceptions (i) when vital for making certain essential power provide throughout the EU or (ii) when the exercise completely considerations a authorized individual working within the power sector in Russia owned by a authorized individual that’s included or constituted below the regulation of an EU member state; and
- export restrictions referring to items or expertise, whether or not or not originating in EU, and technical or monetary help, to any Russian entity appearing within the power {industry} or to be used in Russia (see article 3 and Annex II of Amended Regulation 833).16 However, the prohibition doesn’t apply to the sale or export of products and expertise or associated technical and monetary help vital for the transport of fossil fuels from or by means of Russia into the EU. By derogation, the competent nationwide authorities might authorize the export or sale of focused items or expertise and associated technical/monetary help vital for making certain essential power provide throughout the EU.
The blanket prohibition to carry out any transactions with sure state-owned enterprises (see beneath) consists of main Russian entities appearing within the power sector.17
As specified by our 9 March 2022 consumer alert, the Amended Regulation 833 expanded the sanctions focusing on Russia’s monetary, power and protection sectors which have been in place since 2014, which prohibit, amongst different issues, dealing in new transferable securities (together with fairness and debt devices). Amended Regulation 833 expanded the definition of transferable securities to incorporate securities which are negotiable on the capital markets within the type of crypto belongings.
Sanctions Prohibiting Credit Ratings
The Amended Regulation 833 additionally prohibits as of 15 April 2022 the supply of credit standing companies and subscription companies referring to credit score rankings to any Russian nationwide, any individual residing in Russia or any authorized individual established in Russia.18 This prohibition doesn’t apply to nationals of an EU member state or pure individuals having a brief or everlasting residence allow in an EU member state.
Sanctions on State-Owned Entities
In addition to the sectoral sanctions already imposed on Russian state-owned entities (i.e., debt and fairness restrictions), new measures prohibit partaking in any transaction with publicly-owned or managed Russian entities listed in Annex XIX of Amended Regulation 833. In normal, it’s prohibited to have interaction straight or not directly in any transaction with these entities below any contract concluded on or after 16 March 2022.19 However, the execution of contracts concluded earlier than 16 March 2022, or ancillary contracts vital for the execution of such contracts, will not be prohibited till 15 May 2022.
The identical prohibition applies to transactions with any authorized individual established outdoors the EU that’s greater than 50% owned by a listed state-owned entity, straight or not directly. It additionally applies to transactions with a authorized entity appearing on behalf or on the route of a listed state-owned entity or a non-EU entity greater than 50% owned by a listed stated-owned entity.
However, there are exceptions with respect to transactions which are strictly vital for the acquisition, import or transport of fossil fuels or transactions associated to power tasks outdoors of Russia by which a listed state-owned entity is a minority shareholder.
Amendments to Sanctions Targeting Deposits in Europe by Russian Nationals
The EU prolonged the exemption for deposits over €100,000 at EU credit score establishments on behalf of Russian nationals and residents to exclude nationals and short-term or everlasting residents of an EU member state, international locations throughout the European Economic Area and Switzerland.20
Sanctions Targeting Belarus
The EU prolonged to a few Belarusian credit score establishments the identical ban on using the SWIFT financial institution switch system that applies to some Russian credit score establishments.21 As of 20 March 2022, it’s prohibited to supply specialised monetary messaging companies (that are used to alternate monetary information) to those Belarusian establishments. This prohibition additionally applies to any authorized individual, entity or physique established in Belarus that’s owned greater than 50% by a type of entities. The measures don’t impose an asset freeze however have the impact of eradicating the establishments from SWIFT, undercutting their capability to actively take part within the worldwide monetary system.
The EU additionally prolonged to Belarusians the deposit restrictions that apply to Russians. It is prohibited to just accept deposits exceeding €100,000 from Belarusian nationals, pure individuals residing in Belarus, or authorized individuals, entities or our bodies established in Belarus. The time period “deposit” consists of any credit score steadiness ensuing from funds or transactions. This measure will not be restricted to particularly listed people. In addition, central securities depositories might not present any companies for transferable securities issued after 12 April 2022 to any Belarusian nationwide, resident or authorized individual, entity or physique established in Belarus.
Furthermore, euro-denominated transferable securities issued after 12 April 2022 might not be offered to any Belarusian nationwide, resident or authorized individual, entity or physique established in Belarus. The measures are efficient as of 10 March 2022. They don’t apply to nationals of an EU member state or to deposits vital for non-prohibited cross-border commerce in items and companies between the EU and Belarus.22
Additionally, it’s prohibited to promote, provide, switch or export euro-denominated banknotes to Belarus or any individual in Belarus, together with the federal government and the Central Bank of Belarus or to be used in Belarus.
As of 12 April 2022, it’s also prohibited to listing and present companies on buying and selling venues registered or acknowledged within the EU for the transferable securities of any authorized individual established in Belarus with over 50% public possession.
The EU sanctions prohibit transactions with the Central Bank of Belarus associated to the administration of reserves or belongings, and the prohibition of public financing for commerce with and funding in Belarus. Exceptions could also be granted upon authorization by the competent nationwide authority to be able to safe the monetary stability of the EU as an entire or of one of many member states.
Asset Freezes
The EU amended the EU Consolidated List of Financial Sanctions so as to add 9 entities working within the aviation, army and dual-use, shipbuilding and machine-building sectors23 and 175 people, together with 14 businesspeople in addition to the 146 members of the Russian Federation Council who ratified the Russian authorities’s resolution to acknowledge the Donetsk and Luhansk areas in japanese Ukraine as unbiased nations. New additions additionally embrace individuals enjoying a task in Russia’s efforts to unfold disinformation among the many Russian inhabitants. In complete, 893 people and 65 entities are actually topic to restrictive measures by the EU.
Guidance
The EU Commission is publishing pointers as to the interpretation of the brand new Russia/Belarus sanctions on a rolling foundation within the type of FAQ.24 These pointers complement and seek advice from prior pointers on EU sanctions usually and Russia sanctions particularly.25
Under EU regulation, an entity can be topic to asset-freeze sanctions whether it is owned greater than 50% by a listed individual, or whether it is in any other case “controlled” by a listed individual. In its most up-to-date steering, dated March 20, 2022, the EU Commission acknowledged for the primary time that aggregated possession ought to be taken under consideration relating to the edge of fifty% for an entity to be thought of as being owned by a listed individual within the EU. The Commission acknowledged: “If one listed person owns 30% of the company and another listed person owns 25% of the company, the company should be considered as jointly owned and controlled by listed persons. Dealing with the company could then be considered as making funds or economic resources indirectly available to the listed persons.”
By amending the definition of “transferable securities” in Amended Regulation 833 (as described above), the European Council famous that it was generally understood that the notion of “assets” and “economic resources” topic to freezing additionally consists of crypto belongings, and that loans and credit will also be offered by way of crypto belongings.26
Further Measures
On 17 March 2022, the European Commission introduced an enhanced partnership between the EU’s “Freeze and Seize” activity pressure and the REPO Task Force established by different G-7 nations, together with the US and the UK, to be able to assure the worldwide effectivity of asset freeze sanctions.27
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1 Roman Abramovich, Igor Sechin, Oleg Deripaska, Dmitri Lebedev, Alexei Miller, Andrei Kostin and Nikolai Tokarev.
2 Including Dmitry Peskov (press secretary to President Vladimir Putin), Sergei Shoigu (defence minister of the Russian Federation) and Mikhail Mishustin (prime minister of the Russian Federation).
3 Including Mikhail Fridman, German Khan, Petr Aven and Viktor Vekselberg.
4 Gas Industry Insurance Company SOGAZ, Geopolitica, Internet Research Agency, New Eastern Outlook, Oriental Review, Rosneft Aero and JSC Zelenodolsk Shipyard.
5 The Russia (Sanctions) (EU Exit) (Amendment) (No. 6) Regulations 2022.
6 These restrictions apply to all plane (i) registered in Russia or (ii) owned, chartered or operated by (a) an individual related with Russia or (b) a chosen individual.
7 The authorizations granted by the licence apply to contracts concluded earlier than 8 March 2022 in pursuance of, or in reference to, an association for monetary companies referring to the supply of restricted (i.e. critical-industry, dual-use, army aviation and area) items (i) to an individual related with Russia or (ii) to be used in Russia.
8 Two choices by the Council of the European Union (Council) and three Council laws: Council Decision 2022/429 amending Decision 2014/145/CFSP; Council Decision 2022/430 amending Decision 2014/512/CFSP; Council Implementation Regulation (EU) 2022/427 implementing Regulation 269/2014; Council Regulation (EU) 2022/428 amending Regulation 269/2014; Council Decision 2022/430 amending Regulation (EU) 833/2014.
9 Two Council choices and two Council laws: Council Decision 2022/395 amending Decision 2014/512/CFSP; Decision 2022/399 amending Decision 2012/642/CFSP; Council Regulation (EU) 2022/394 amending Regulation (EU) 833/2014; Council Regulation (EU) 2022/398 amending Regulation (EC) No 765/2006.
10 Council Regulation (EU) No 833/2014 of July 31, 2014, regarding restrictive measures in response to Russia’s actions destabilizing the state of affairs in Ukraine, as amended: See Official Journal of the European Union 229, Vol. 57 p.1.
11 This additionally applies to Belarus (Council Regulation (EU) 2022/355 of two March 2022 amending Regulation (EC) No 765/2006).
12 See Art. 3h and Annex XVIII Regulation 833, as amended by Regulation (EU) 2022/428.
13 See Art. 3f Regulation 833, as amended by Regulation (EU) 2022/394. In addition, on 9 March 2022, the Russian Maritime Register of Shipping was added to the listing of state-owned enterprises topic to the prohibitions on dealing in transferable securities and granting new loans/credit.
14 On 16 March 2022, the EU issued a FAQ on export-related restrictions referring to Russia and the Ukrainian state of affairs pursuant to Articles 2, 2a and 2b of Regulation 833.
15 Regulation 833, as amended by Regulation (EU) 2022/428, excludes the civil nuclear {industry} from the restrictions.
16 The prohibitions don’t apply to the execution till 17 September 2022 of an obligation arising from a contract concluded earlier than 16 March 2022, or ancillary contracts vital for the execution of such a contract, offered that the competent authority has been knowledgeable at the least 5 working days prematurely.
17 See article 5aa and Annex XIX of Regulation 833, as amended by Regulation (EU) 2022/428.
18 See Art. 5j Regulation 833, as amended by Regulation (EU) 2022/428.
19 Opk Oboronprom, United Aircraft Corporation, Uralvagonzavod, Rosneft, Transneft, Gazprom Neft, Almaz-Antey, Kamaz, Rostec (Russian Technologies State Corporation), Jsc Po Sevmash, Sovcomflot and United Shipbuilding Corporation.
20 See Art. 5b No. 2 Regulation 833, as amended by Regulation (EU) 2022/394.
21 Belagroprombank, Bank Dabrabyt and Development Bank of the Republic of Belarus.
22 See Article 1u No. 2, Article 1x No. 2 Regulation (EC) No 765/2006, as amended by Regulation (EU) 2022/398.
23 Rosneft Aero, JSC Rosoboronexport, JSC NPO High Precision Systems, JSC Kurganmashzavod, JSC Russian Helicopters, PJSC United Aircraft Corporation, JSC United Shipbuilding Corporation, JSC Research and Production Corporation Uralvagonzavod and JSC Zelenodolsk Shipyard.
24 See on the EU Commission web site, “Sanctions Adopted Following Russia’s Military Aggression Against Ukraine, Frequently Asked Questions.”
25 See, e.g., EU Commission’s “Frequently Asked Questions: Restrictive Measures (Sanctions)” (revealed 26 February 2022) and the Commission Guidance Note on the Implementation of Certain Provisions of Regulation (EU) No 833/2014 (final up to date 25 August 2017).
26 See recital 4 Regulation (EU) 2022/394 amending Regulation 833.
27 See European Commission Press Statement, “Enforcing Sanctions Against Listed Russian and Belarussian Oligarchs: Commission’s ‘Freeze and Seize’ Task Force Steps Up Work With International Partners” (March 17, 2022).
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