This represents Danske Bank’s briefing to our clients on the situation as of 18.00 (CET) 07 October 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. A number of other Russian financial institutions became subject to blocking sanctions, most notably VTB Bank, the second largest bank in Russia. Additionally, the Export Administration Regulations have been widened to include restrictions on exports to Russia. 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. 
  

• 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 members of Russia’s defence sector, while also re-designating the president of Belarus. 
  
  
• On 24 March, the US designated 328 members of the Russian State Duma, 48 Russian defence companies, and the 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 was 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 Transkapitalbank, 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. 
  
  
• On 28 April, the US proposed new measures targeting oligarchs. 
  

• On 8 May, the US identified accounting, trust, corporate formation, and management consulting as categories of services subject to a prohibition on the export, re-export, sale, or supply, directly or indirectly to any person located in the Russian Federation. Operating in these sectors in Russia is now sanctionable. The US also imposed sanctions against 34 individual and 23 entities, including 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.
  
  
• On 2 June, the US added 71 parties located in Russia and Belarus to the BIS Entity List and designated a number of prominent Russian government officials and business leaders, luxury property of elites, and luxury asset management and service companies.
  
  
• On 28 June, the US prohibited the importation of gold of Russian Federation origin and designated 115 entities, many of which are critical to the Russian Federation’s defense industrial base, including State Corporation Rostec involved in Russia’s defense, industrial, technology, and manufacturing sectors, as well as 58 individuals. The action was jointly carried out by the Treasury Department and State Department, and was accompanied by an alert issued with the Commerce Department, advising vigilance against Russian and Belarusian export control evasion.
  
  
• On 19 July, US President Joe Biden signed Executive Order 14078, aimed at bolstering efforts to bring hostages and wrongfully detained United States Nationals home. The E.O. creates new ways to impose costs on malicious actors who take hostages and thus threaten the integrity of the international political system and the safety of U.S. nationals and other persons abroad. As such, the E.O. establishes the framework of a new Sanctions regime, though as of today, no individuals or entities have been listed under this E.O. 
  
  
• On 30 September, the US designated 14 persons in Russia’s military-industrial complex, including two international suppliers, three key leaders of Russia’s financial infrastructure, immediate family members of some of senior Russian officials, and 278 members of Russia’s legislature for enabling Russia’s sham referenda and attempt to annex sovereign Ukrainian territory.

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 designating Otkritie FC Bank, Novikombank, Sovcombank, and VTB Bank. 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, 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, and 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. 

• On 3 June, the EU put into law a 6th package of sanctions, composed of the following: An Embargo on the import of crude and refined oil products, and, after a wind down period of 6 months, EU operators will be prohibited from insuring and financing the transport of Russian oil to third countries; Russian banks, including Sberbank, and one Belarussian bank have been removed from SWIFT. The provision of certain business-relevant services to the Russian government, as well as to Russian legal persons, entities or bodies, are prohibited; the broadcasting activities of another three Russian State outlets have been suspended, and the list of advanced technology items banned from export to Russia (and a further 24 Belarussian entities) has been expanded to include additional chemicals that could be used in the process of manufacture of chemical weapons. The EU has also designated an additional 65 individuals and 18 entities. 
  
  
• On 7 July, the EU adopted its 7th package of sanctions countering Russian aggression in Ukraine. The package includes a new import ban on Russian gold, reinforcement of the EU’s dual-use and advanced technology export controls and strengthened reporting requirements to tighten EU asset freezes. The sanctions package also reiterates that EU sanctions do not target in any way the trade in agricultural products between third countries and Russia. 
   
  
• On 6 October, the EU adopted its 8th package of sanctions countering Russian aggression in Ukraine. The package includes designations of a further 30 individuals and 7 entities involved in Russia's occupation, illegal annexation, and sham “referenda” in the occupied territories/oblasts of Donetsk, Luhansk, Kherson, and Zaporizhzhia regions. Individuals and entities working in the defence sector, and actors who spread disinformation about the war. Restrictions have also been extended to the oblasts of Kherson and Zaporizhzhia.
  Other measures include: 
  • Export restrictions on coal including coking coal (which is used in Russian industrial plants), specific electronic components (found in Russian weapons), technical items used in the aviation sector, as well as certain chemicals. A prohibition on exporting small arms and other goods under the anti-torture Regulation has been added.
  • Import restrictions, a ban on all Russian finished and semi-finished steel products, machinery and appliances, plastics, vehicles, textiles, footwear, leather, ceramics, certain chemical products, and non-gold jewellery
  • An Oil price cap is expected to be introduced from 5 December 2022 for crude and 5 February 2023 for refined petroleum products, after a further decision by the Council.
  • EU nationals are banned from holding posts in the governing bodies of certain state-owned enterprises.
  • There will be a ban on all crypto-asset wallets, accounts, or custody services, irrespective of the amount of the wallet (previously up to €10,000 was allowed).
  • Services that can no longer be provided to the government of Russia or legal persons established in Russia now include IT consultancy, legal advisory, architecture and engineering services.

  A new listing criterion has been announced for those that evade, or assist in evading, sanctions. 

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 and 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 and Gazprombank. 
  
  
• On 31 March, 17 individuals and entities were designated. The total UK designations under its Russia and Belarus sanctions regimes now encompasses over 1,300 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. The UK also 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 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 5 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 9 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. 
  
  
• On 13 May, the UK announced sanctions on Putin’s ‘Inner Circle’ including his ex-wife and 11 close personal associates. 
  
  
• On 19 May, the UK designated State-owned Aeroflot, Russia’s largest airline, Ural Airlines and Rossiya Airlines. They will now be unable to sell their unused landing slots at UK airports.
  
  
• On 16 June, the UK designated 12 individuals. The measures include the sanctioning of Russian Children's Rights Commissioner for alleged involvement in the forced transfer and adoption of Ukrainian children.
  
  
• On 23 June, the UK announced bans on the export to Russia and the non-government controlled Ukraine territories of:
  
  • Goods and technology with potential use for internal repression or the production and development of chemical and biological weapons, and on the provision of related services
  • Export of maritime goods and technology
  • Export to (or for use in) Russia of Sterling or EU denominated banknotes
  • Making available, supply, or delivery of Sterling or EU denominated banknotes to a person connected with Russia
  • Export to (or for use in) Russia of jet fuel and fuel additives, and on the provision of related services
  • Import, acquisition or supply and delivery of revenue generating goods that originate in or are consigned from Russia, and on the provision of related services
  • Provision of services relating to iron and steel imports
    

The UK also added products to existing prohibitions relating to oil refining goods and technology and extended existing Russia export/transfer bans on military goods and technology to non-government controlled Ukrainian territory.

• On 29 June, the UK announced a ban on Russia accessing UK trusts services and designated 8 individuals, including Vladimir Potanin, Russia’s second richest man, and 5 entities. 
  
  
• On 21 July, the UK imposed new trade restrictions on Russia. The listing includes expanded prohibitions on energy-related goods and services. Provision of accounting, business and management consulting, and public relations services to persons connected to Russia. Import, acquisition and supply or delivery of: oil and oil products (enters into force on 31 December 2022); and coal and coal products (enters into force on 10 August 2022); that originate in or are consigned from Russia, as well as related services. Import, acquisition or supply and delivery of gold that originates in Russia on or after the 21 July 2022, as well as ancillary services.
  
  
• On 26 July, the UK designated 41 individuals and 1 entity, including a British National. The designations primarily targeted members of the Russian government and leaders of the self-proclaimed Donetsk and Luhansk’s People’s Republics. 
  
  
• On 30 September, the UK announced further sanctions in relation to the illegal annexation of the Ukrainian regions of Donetsk, Luhansk, Kherson and Zaporizhzhia following sham referendums. Under new sanctions Russia will lose access to major western services, including: IT consultancy, architectural services, engineering services, and transactional legal advisory services for certain commercial activity. The UK has also banned the export of nearly 700 goods that are crucial to Russia’s industrial and technological capabilities.
  
  
  

• 0n 27 June, the G7 outlined further commitments to isolate Russia from participating in the global market, tackling sanctions evasion, reducing Russia’s revenues, including from gold, reducing dependency on Russian energy, coordinating tariff measures on imports from Russia aligning and expanding sanctions to restrict Russia’s access to key industrial inputs, services and technologies, particularly those supporting Russia’s armament industrial base and technology sector, imposing sanctions on those responsible for war crimes and those exercising illegitimate authority in Ukraine linked to the theft and export of Ukrainian grain, or otherwise profiting illegitimately from the war. 
  
  
• On September 23, G7 Leaders issued a statement condemning Russia’s sham referenda and noting their collective readiness to impose further economic costs on Russia, and on individuals and entities both inside and outside of Russia that provide political or economic support for Russia’s illegal attempts to change the status of Ukrainian territory, including the introduction of an Oil Price Cap on 3rd countries, which is expected to come into force before the end of the year.