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The European Union has imposed a range of financial sanctions against Russia in the last few days. Below is an overview of the various sanctions.
This sanctions package includes a prohibition to register, provide a registered office, business address, administrative address or management services to a trust – by which is meant the Anglo-Saxon legal form, rather than a trust office that we supervise. It also includes a prohibition to purchase, import or transfer coal from Russia into the EU as from August 2022 and a prohibition to provide access to EU ports to vessels registered under the flag of Russia.
This package includes measures against the Belarusian financial sector. The European Union will ban several Belarusian banks from the SWIFT payments system. The measures also prohibit transactions with the Central Bank of Belarus related to the management of reserves or assets. In addition, they prohibit the acceptance of deposits exceeding €100,000 from Belarusian nationals or residents. The provision of euro-denominated banknotes to Belarus will also be prohibited.
Lastly, the European Council clarified the notion of “transferable securities” so as to clearly include crypto-assets.
The official sanction measures are laid down in intricate legal texts. The press releases issued by the European Union provide an explanation of what the sanctions entail. We have summarised them below. The DNB & AFM sanctions alerts provide an overview for the financial sector.
Under this package, the European Union (EU) bans seven Russian banks from SWIFT system. The prohibition will enter into force on the tenth day after the publication in the Official Journal of the EU.
In addition, it is prohibited to sell, supply, transfer or export euro-denominated banknotes to Russia or to any natural or legal person, entity or body in Russia, including the government and the Central Bank of Russia, or for use in Russia.
The EU has also prohibited to invest or participate in, or otherwise contribute to projects co-financed by the Russian Direct Investment Fund.
This package prohibits transactions with the Central Bank of Russia or with legal persons, entities or bodies acting on behalf of or at the direction of the Central Bank of Russia.
The EU has imposed sanctions on President Putin and Foreign Minister Lavrov and has adopted an additional package of individual and economic sanctions, which also affect Belarus.
Within the existing sanctions framework, the EU has extended the restrictive measures to all 351 members of the Russian Duma.
In addition, restrictive measures have been imposed on another 27 prominent persons and entities, including policymakers such as members of the government, banks and businessmen/oligarchs, senior military officers and persons leading a disinformation war against Ukraine. The restrictive measures include a freezing of assets and a prohibition on making funds available to the persons and entities on the sanctions list.
There are also restrictions on economic relations with the Donetsk and Luhansk regions to and from the EU. They provide for a ban on the import of goods from Donetsk and Luhansk, restrictions on trade and investment related to certain economic sectors, a ban on the provision of tourist services, and a ban on the export of certain goods and technologies.
Furthermore, a sectoral ban on financing the Russian Federation, its government and the Central Bank of Russia has been imposed. Access of the Russian state and government to the capital and financial markets and services in the EU has been restricted with the aim of limiting the financing of escalating and aggressive policies.
The EU has indicated that it is ready to adopt even tougher political and economic sanctions quickly if necessary.
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