Reed Smith In-depth

In the wake of Russia’s aggression against Ukraine, the EU has adopted in rapid succession a series of sanctions against Russia and against Belarus for its support of Russia in the conflict. With each successive layer of sanctions, the EU is in the process of imposing an outright economic boycott against these two countries, one that continues to be tightened as the conflict intensifies. These sanctions are the most far reaching measures the EU has ever imposed and were imposed in coordination with the EU’s major allies.

The EU sanctions packages include sanctions against key sectors of the economy and targeted restrictive measures against prominent entities and business leaders, including Vladimir Putin himself. New sanctions also include some of the most restrictive seen to date against energy majors such as Rosneft and Gazprom Neft. 

To help you keep track of these measures, your Reed Smith sanctions team has put together the detailed summary below.

Targeted restrictive measures: targeted restrictive measures have been gradually extended as the conflict has progressed, starting first with some high-profile individuals and members of the Russian State Duma, expanding to the president, Vladimir Putin, and prominent business leaders in Belarus, and culminating most recently with the designation of key oligarchs, such as Roman Abramovich.

23 February 2022

Council Decision (CFSP) 2022/267 and Council Implementing Regulation (EU) 2022/261 

  • 336 members of the Russian State Duma 

Council Decision (CFSP) 2022/265 and Council Implementing Regulation (EU) 2022/260

  • 22 high-profile individuals (e.g., government and senior military officials, individuals working for pro-Russian media, and business leaders/oligarchs)
  • 4 entities. The first entities to have been made subject to an asset freeze are the Internet Research Agency and three Russian banks:
    • Rossiya,
    • Promsvyazbank
    • VEB.RF

Regulation (EU) 2022/259 however provided for a wind-down period until 24 August 2022 for contracts involving the three designated banks concluded before 23 February 2022. 

25 February 2022 

Council Decision (CFSP) 2022/331 and Council Implementing Regulation (EU) 2022/332

  • Members of the National Security Council, additional members of the Russian State Duma and persons who facilitated the Russian military aggression from Belarus. Vladimir Putin is made subject to an asset freeze. 

28 February 2022

Council Decision (CFSP) 2022/337 and Council Implementing Regulation (EU) 2022/336

  • Additional sanctions against 26 major business leaders and oligarchs, and one entity (the Gas Industry Insurance Company SOGAZ). 

2 March 2022

Council Decision (CFSP) 2022/354 and Council Implementing Regulation (EU) 2022/353

  • 22 Belarusian individuals added for their support of Russia in the invasion of Ukraine.