Ukraine Crisis: Global Sanctions Developments – Updated April 9, 2022

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In light of the current conflict and crisis in Ukraine, we are tracking the evolving sanctions imposed by several governments on Russia and Russia-aligned regions and certain individuals. The jurisdictions in focus are: EUJapanRepublic of KoreaUK  and US.

Latest Developments:

US – April 9, 2022: BIS issued a final rule imposing “highly restrictive” license requirements on all Commerce Control List categories to Russia and Belarus. The move “expands U.S. scrutiny of transactions to almost any sensitive dual-use technology, software, or commodities that could be used to support Russia’s war effort.” BIS will apply a policy of denial to such license applications.

April 7, 2022:

  • BIS issued three Temporary Denial Orders (TDOs) denying the export privileges of three Russian airlines: Aeroflot, Azur Air, and UTair. The TDOs were based on “ongoing export violations related to comprehensive export controls on Russia imposed by the Commerce Department.” The three TDOs function to terminate the right of the listed airlines “to participate in transactions subject to the Export Administration Regulations (EAR), including exports and reexports from the United States.” The TDOs are for a period of 180 days and may be renewed.
  • Pursuant to EO 14024, OFAC designated Public Joint Stock Company Alrosa, the world’s largest diamond mining company. Additionally, the Department of State re-designated Joint Stock Company United Shipbuilding Corporation (USC), including 28 subsidiaries and eight board members.

See complete tracker for US.

EU – March 24, 2022: The Council issued a Joint Readout with the US President affirming the readiness to adopt additional measures and stop attempts to circumvent sanctions. The Council Conclusions also note the EU’s readiness to move quickly with coordinated sanctions on Russia and Belarus.

See complete tracker for EU.

Japan – March 25, 2022: Japan adds 25 Russian individuals and 81 Russian entities to its sanctions list and freezes their assets. Japan also imposes an export ban on luxury goods destined to Russia next week. Japan is also drafting legislation related to digital assets to ensure that sanctioned individuals and entities cannot evade sanctions.

See complete tracker for Japan.

UK – March 24, 2022: UK Government announced 65 new sanctions targeting strategic industries, banks and business elites.

See complete tracker for UK.

Please contact us with any questions.