Responses to the Russia/Ukraine Crisis - Sanctions Update No. 9

Back in February 2022, when Russia commenced its full-scale invasion of 
Ukrainian territory, few would have thought that three years on, the fighting 
would be continuing. It is possible that the current negotiations will make 
proceed and an end to the conflict on the ground may be in sight. 
Nonetheless, it seems unlikely that the vast, complicated and global 
structure of legal, financial and trade restrictions on Russian businesses, 
individuals and other related parties will be dismantled as a consequence. 

Indeed, the EU has recently introduced two fresh packages of sanctions 
particularly targeting Russia’s so-called “shadow fleet” and strategically 
important sectors of the Russian economy, such as energy, transport, 
infrastructure and financial services. The UK has imposed new reporting 
obligations on a large number of additional business sectors and continues 
to designate individuals, entities and ships. In the last few months, the U.S. 
has expanded sanctions with regard to Russia’s energy sector, continued to 
designate actors that participate in Russia’s sanctions evasion network and 
prosecuted cases relating to U.S. export controls violations. European allies 
continue to apply pressure on the Russian economy, cutting off sources of 
revenue from oil, coal and other valuable products and limiting access to 
global funds. Other countries, including Switzerland, Australia, New Zealand, 
Canada and Japan, have adopted similar regimes.

However, it is clear that Russia is succeeding in evading sanctions and 
accessing trade and economic benefits from third party states, including 
Belarus, Iran, North Korea and, increasingly, China. The U.S., and to a 
lesser extent, the UK and EU, have imposed additional sanctions on these 
states as a result of their support of Russia, targeting in particular the 
provision of military equipment. The use of further secondary sanctions on 
such states would add another layer of legal technicality to be navigated by 
businesses and organisations operating in the global arena. 

In this our ninth update on the sanctions imposed on Russia and its allies by 
the UK, EU and U.S. since February 2022, we leave aside recent political 
proposals and focus on the latest legal developments in sanctions regimes 
and their enforcement.