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  This represents Danske Bank’s briefing to our clients on the situation as of 09.00 (CET) 18 May 2022.
  
  

  US actions:
  

  • On 21 February, the US implemented a comprehensive embargo on the so-called Donetsk and Luhansk People’s Republics (DNR and LNR). The following day, the US imposed sanctions on two Russian state-owned financial institutions and additional restrictions on dealings in Russian sovereign debt.
    
    
  • On 24 February, further sanctions were announced, cutting SBERBANK off from the US financial system. Further, a number of other Russian financial institutions have become subject to blocking sanctions, most notably VTB Bank, the second largest bank in Russia (a General License, which permitted the wind-down of transactions involving VTB and its majority owned subsidiaries, expired on 26 March 2022). Additionally, the Export Administration Regulations have been widened to include restrictions on exports to Russia, and capital market restrictions have been implemented.
    
    
  • On 25 February, the US imposed blocking sanctions on Vladimir Putin, President of the Russian Federation and Sergey Lavrov, Minister of Foreign Affairs of the Russian Federation.
    
    
  • On 28 February, a prohibition was implemented on any transactions involving the Central Bank of the Russian Federation, the National Wealth Fund, and the Ministry of Finance.
    
    
  • On 3 March, the US designated 92 individuals, entities, vessels and aircrafts linked to Russian elites and intelligence-directed information outlets.
    
    
  • On 8 March, the US announced a ban on the importation into the United States of crude oil, petroleum, petroleum fuels, oils, and products of their distillation, liquefied natural gas, coal, and coal products of Russian origin, as well as new investment in the energy sector in Russia (wind-down of the prohibited activities are permitted until 22 April 2022).
    

  • On 11 March, the US announced a ban on the importation into the US of Russian fish, seafood, alcoholic beverages, non-industrial diamonds, as well as the export of Luxury goods and US dollar-denominated banknotes to Russia. The US also put legal authorities in place to prohibit any future investments into any sector of the Russian economy. 
    
    
  • On 15 March, the US announced sanctions on 11 key members of Russia’s defence sector, while also re-designating president of Belarus.
    
    
  • On 24 March, the US designated 328 members of the Russian State Duma, 48 Russian defense companies, and Herman Gref, CEO of SBERBANK.
    
    
  • On 31 March, the US further designated 34 individuals and entities, including Joint Stock Company Mikron, the largest Russian manufacturer and exporter of microelectronics. On 31 March, the US also published a determination, pursuant to Executive Order 14024, which added three new sectors (aerospace, electronics, and marine) of the Russian economy to the scope of the sanctions. This allows the US to impose sanctions on any individual or entity determined to operate or have operated in any of those sectors.
    
    
  • On 6 April, the US imposed full blocking sanctions on Sberbank and 42 of its subsidiaries, as well as Alfa Bank and 5 of its subsidiaries inside and outside of Russia. The US also designated the Russian Security Council members, and family members of Vladimir Putin. In addition, a new Executive Order has been adopted, prohibiting new investment in and certain services to the Russian Federation.
    
    
  • On 7 April, the US designated Alrosa, a Russian state-owned enterprise and the world’s largest diamond mining company. United Shipbuilding Corporation, as well as its subsidiaries and board members, were also designated. 
    
    
  • On 9 April, the US tightened controls on the export and re-export of US-origin and certain foreign-produced commodities, software, and technologies to Russia and Belarus and introduced highly-restrictive licensing requirements.
    
    

  • On 20 April the US designated Russian commercial bank Transkapitalbankha, as well as a global network of more than 40 individuals and entities led by Russian oligarch Konstantin Malofeyev, including organizations whose primary mission is to facilitate sanctions evasion for Russian entities. The US also designated companies operating in Russia’s virtual currency mining industry, reportedly the third largest in the world. This is the first time US has designated a virtual currency mining company.
    
    
  • On 28 April, the White House announced that President Biden was proposing new measures targeting Oligarchs, including a streamlined administrative process for the forfeiture of US property that is owned by listed Oligarchs and linked to specified unlawful conduct.
    
    
  • On 29 April the US imposed sanctions and visa restrictions on numerous people in response to human rights abuses committed in Russia and Belarus. The measures included visa restrictions on 587 Russians, including members of the State Duma, and a further 65 people believed to have undermined political independence of Ukraine, or said to be responsible for undermining democracy in Belarus. 16 Bank Otkritie board members were also designated.

  • On 08 May the US identified accounting, trust, corporate formation, and management consulting as categories of services that are subject to a prohibition on the export, reexport, sale, or supply, directly or indirectly to any person located in the Russian Federation. Operating in these sectors in Russia is now deemed sanctionable. The US also imposed sanctions against 34 individual, 23 entities, including the board members of two of Russia’s most important banks, a Russian state-owned bank and 10 of its subsidiaries, a state-supported weapons manufacturer, and three of Russia’s state-controlled television stations.
    

  EU actions:

  • On 24 February, the EU placed restrictions on activity involving the DNR and LNR and has limited Russia’s ability to raise capital on the EU's financial markets. The EU also targeted Russian government officials and elected officials. Furthermore, Bank Rossiya, Vnesheconombank and Promsvyazbank have been sanctioned.
    
    
  • On 25 February, the EU imposed asset freezing on Vladimir Putin and Sergey Lavrov.
    
    
  • On 28 February, the EU expanded its existing sanctions on Russia’s financial sector by, for example, prohibiting listing and the provision of services for shares of Russian state owned- entities and the acceptance of deposits from Russian nationals, residents or entities established in Russia exceeding €100,000. In addition, the EU adopted a ban on transactions with the Central Bank of Russia while it also designated 26 individuals and entities.
    
    
  • On 2 March, the EU prohibited the selling, supplying, transferring and exporting of euro denominated banknotes to Russia and to Russian persons and entities. Furthermore, the EU released a greatly expanded sanctions package for Belarus which targets most major sectors of the Belarussian economy, including tobacco, mineral fuels, bituminous substances and gaseous hydrocarbon products, potassium chloride products, wood products, cement products, iron and steel products and rubber products.
    

  • On 9 March, the European Union imposed additional restrictive measures on Belarus, including exclusion of certain Belarusian financial institutions from SWIFT, as well as financial restrictions almost identical to those levied against Russia. The EU further implemented export bans on Russia and imposed asset freezing measures on 160 individuals. Notably, the EU clarified the prohibitions on “transferrable securities” to also include crypto-assets which are negotiable on the capital market, and provided definitions of other provisions of the financial restrictions targeting Russia and Belarus.
    
    
  • On 15 March, the EU published its fourth sanctions package, which imposed sanctions on an additional 15 individuals and 9 entities. The EU also widened the scope of its sectoral sanctions by prohibiting all transactions with certain Russian State-owned enterprises, imposed an import ban on certain steel products, banned new investment across the Russian energy sector, with limited exceptions for civil nuclear energy and the transport of certain energy products back to the EU. The EU also imposed an export ban on luxury goods and prohibited EU credit rating agencies to rate Russia and Russian companies, as well as providing rating services to Russian clients.
    
    
  • On 8 April, the EU put into law a 5th package of sanctions, which imposes restrictions against Russia, including by:
    • Designating an additional 216 individuals and 18 entities, including Otkritie FC Bank, Novikombank, Sovcombank, and VTB Bank. These banks are now subject to a full transaction ban and asset freeze
    • Prohibiting the purchase, import or transfer coal and other solid fossil fuels into the EU, if they originate in Russia or are exported from Russia
    • Introducing further export restrictions to Russia, in particular on jet fuel, and goods which could contribute to the enhancement of Russia’s industrial capacities
    • Prohibiting access to EU ports to vessels registered under the flag of Russia. Derogations are granted for agricultural and food products, humanitarian aid, and energy
    • Prohibiting the award and continued execution of public contracts and concessions with Russia
    • Imposing additional import bans, including on cement, rubber products, wood, spirits, liquor, high-end seafood and an anti-circumvention measure against potash imports from Belarus
    • Prohibiting the provision of support, including financing and financial assistance or any other benefit, to Russian publicly owned or controlled entities
    • Prohibiting road transport undertakings established in Russia to transport goods by road in the EU, and access to ports to vessels registered under the flag of Russia
    • Introducing a prohibition on being a beneficiary, acting as a trustee or in similar capacities for Russian persons and entities, as well as a prohibition on providing certain services to trusts
    • Extending the prohibitions on the export of euro-denominated banknotes and on the sale of euro-denominated transferrable securities to all official currencies of the EU
    • Prohibiting high-value crypto-asset services to Russia.

  • On 13 April, the EU announced exceptions to the relevant sanctions that allow clearly defined categories of bodies, persons, entities, organisations and agencies to provide goods and technology in the non-government-controlled areas of the Donetsk and Luhansk oblasts of Ukraine or for use in those areas, where necessary for humanitarian purposes.

  • On 21 April, 2 individuals were designated.
    
    
  • On 4 May, the EU announced a 6th package of EU sanctions on Russia. The measures, which have not yet been put into law, will include: 
    • Designations of high-ranking military officers said to have committed war crimes in Bucha and those said to be responsible for the siege of Mariupol
    • Removal of Sberbank and 2 other banks from SWIFT 
    • Ban on 3 Russian state-owned broadcasters 
    • Export ban on accountancy, consultancy and “spin doctor” services 
    • Import ban on all Russian oil. The import of Russian crude oil will be phased out within 6 months and the import of refined products by the end of 2022
    The EU has further removed Russia as a permitted destination for dual-use general export authorisations.

  UK actions:

  • On 22 February, the UK sanctioned three individuals and five banks. In addition, the UK government announced sanctions on DNR and LNR.
    
    
  • On 24 February, further sanctions were announced  which included asset freezing sanctions on over 100 individuals and entities, including VTB Bank. Aeroflot and Russian commercial and private jets have been banned from UK airspace, and new export controls were put into place.
    
    
  • On 25 February, the UK issued a General License related to VTB, allowing certain wind-down activities. The UK also imposed asset freezes on President Putin and Sergei Lavrov.
    
    
  • On 28 February, the UK designated an additional 3 Russian financial institutions.
    
    
  • On 1 March, the UK extended its export controls, shipping sanctions, broad financial and investment restrictions, and included Sberbank on its list of targeted entities, and issued a number of wind-down authorizations. The UK also designated a number of persons and entities, including the Russian Direct Investment Fund and its CEO and imposed financial restrictions on the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation and the Ministry of Finance of the Russian Federation.
    
    
  • On 3 March, further designations were made. 
     
    
  • On 9 March, the UK made further designations of individuals, including designation of the owner of the Chelsea Football Club.
    
    
  • On 11 March, the UK designated 386 members of the Russian State Duma.
    
    
  • On 15 March, the UK designated 373 entities and individuals and announced a ban on exports of high-end luxury goods to Russia.
    
    
  • On 24 March, the UK designated 65 individuals and entities under its Russia and Belarus sanctions regime, including Alfa-Bank Russia.
    
    
  • On 31 March, 17 individuals and entities were designated. The total UK designations under its Russia and Belarus sanctions regimes now encompasses over 1,000 individuals and entities.
    
    
  • On 1 April, the UK amended a General License to allow payments in connection with insolvency proceedings for the UK subsidiary of VTB until March 2023. On 6 April, the UK made further designations, including of Sberbank and the Credit Bank of Moscow. Certain wind-down authorizations will apply, including to energy payments.
    
    
  • On 6 April, the UK designated further individuals and entities, including asset freezes against Sberbank and Credit Bank of Moscow, and an outright ban on all new outward investment to Russia. The export of key oil refining equipment and catalysts will also be banned, as well as on imports of iron and steel products. A further eight oligarchs active in these industries were designated.
    
    
  • On 8 April, the UK imposed sanctions on family members of Vladimir Putin and Foreign Minister Sergey Lavrov.
    
    
  • On 13 April the UK designated a further 178 individuals, targeted as a result of their involvement in propping up separatist regions of Ukraine, as well as 28 other individuals, including Oligarchs and their families.
    
    
  • On 14 April, the UK expanded export restrictions on luxury goods, quantum computing and advanced materials goods and technology, oil refining goods, and iron and steel products. Such goods are now prohibited for export, supply or transfer to, or for use in, Russia or to a person connected with Russia. The UK also designated 2 individuals for connections to Roman Abramovich.
    
    
  • On 21 April, the UK announced further trade sanctions against Russia to include import bans on silver, wood products and high-end products from Russia, including caviar. Tariffs have been increased by 35 percentage points on around £130m worth of products from Russia and Belarus, including diamonds and rubber. The UK also sanctioned a further 26 individuals and issued two General Licenses for the purpose of making gas available for use in the EU.
    
    
  • On 29 April, the UK introduced new Russia trade sanctions centred on preventing UK-based users from accessing social media services, internet access services and application stores provided by a designated person/entity.

  • On 30 April the UK enacted a general licence allowing for non-crown regulatory authorities such as the Financial Conduct Authority (UK Regulator) to carry out their duties as necessary.
    
    
  • On 4 May, the UK announced a ban on service exports, including management consulting, accounting and public relations, to Russia, as well as the designations (asset freezes and travel bans) of 31 people and 32 entities.

  • On 05 May the UK announced it was sanctioning EVRAZ PLC, a steel manufacturing and mining company that has operations in Russia, the US, Canada and Kazakhstan.
    
    
  • On 09 May the UK announced plans for measures which will impose an additional 35% import tariff on £1.4 billion worth of goods from Russia and Belarus, including platinum and palladium, and export bans covering £250 million worth of goods in sectors of the Russian economy most dependent on UK goods, including chemicals, plastics, rubber and machinery. Legislation will be laid in due course to implement these measures.
    
    
  • On May 13 the UK designated 12 people said to be part of Russian President Putin’s personal and financial “inner circle”.
    

  Russian counter-sanctions against Gazprom Subsidiaries
  On May 11 the Russia state banned Russian people and entities from engaging in transactions with or fulfilling obligations towards 31 entities, including EuRoPol Gaz s.a., Gazprom Germania GmbH, Wingas GmbH and 28 other Gazprom Germania subsidiaries. Restrictions further apply to export of Russian-origin products and raw materials and restrictions on entry into Russian ports by vessels linked to them. Gazprom Germania and its subsidiaries, who operate gas storage facilities and gas trading in Germany and are co-owners of gas pipelines, went under stewardship by German regulators in April. Following the counter-sanctions, it has been reported that the German government is inching closer to expropriating the German Gazprom subsidiary and related assets.