Further tightening of sanctions against Russia and Belarus
Again, the basic legislation (Regulation (EU) 833/2014 concerning restrictive measures against Russia, Regulation (EU) No 269/2014 concerning measures in response to threats to the territorial integrity, sovereignty and independence of Ukraine, and Regulation (EU) 765/2006 concerning restrictive measures against Belarus) were amended, essentially adding more individuals to the list of persons subject to travel and financial sanctions and in particular expanding the capital markets-related sanctions for Belarus.
The restrictive measures that were introduced include the following:
Extended scope of sanctions relating to goods and capital markets
With regard to Russia, a prohibition of the sale, supply, transfer and export of maritime navigation goods and technologies specified in the Regulation has been added (Articles 3-4 of newly amended Regulation (EU) No 833/2014); in addition, the Russian Maritime Register of Shipping is now listed as one of the state-owned companies for which financing restrictions are in force.
The prohibition of trading in transferable securities and money-market instruments of credit institutions comprising the Central Bank of Russia now also includes a ban on transactions in connection with the management of reserves and assets of the Central Bank of Russia (Article 5a (4) of newly amended Regulation (EU) No 833/2014).
An identical prohibition has been introduced for reserves and assets of the Central Bank of Belarus (Article 1ja of newly amended Regulation (EU) 765/2006). With regard to Belarus, it is now prohibited to provide public financing or financial assistance for trade with, or investment in, Belarus (Article 1t of newly amended Regulation (EU) 765/2006) to accept large deposits from Belarusian nationals or natural persons residing in Belarus, or legal persons, entities or bodies established in Belarus (Article 1u of newly amended Regulation (EU) 765/2006) as well as to sell euro-denominated transferable securities to any Belarusian national or natural person residing in Belarus or any legal person, entity or body established in Belarus (Article 1y of newly amended Regulation (EU) 765/2006). This does not apply to nationals of any EU Member State or nationals of third countries who have a residence permit in a Member State.
As for Russia, the sale or supply of euro-denominated banknotes to any natural or legal person, entity or body in Belarus is now prohibited (Article 1za of newly amended Regulation (EU) 765/2006). Finally, three Belarusian banks were also included in the exclusion from the SWIFT system: as of 20 March 2022, it is prohibited to provide specialised messaging services for payment transactions used for the exchange of financial data for the banks Belagroprombank, Bank Dabrabyt and Development Bank of the Republic of Belarus or companies of whose proprietary rights the listed banks own directly or indirectly more than 50 % (Article 1zb of newly amended Regulation (EU) 765/2006).
Individual sanctions
The list of persons subject to the personal financial and travel restrictions has been expanded by 160 entries. The persons now listed are oligarchs, business people and members of the Russian Federation Council. The listing of Alexander Semenovich VINOKUROV, Andrey Igorevich MELNICHENKO (associated with the companies EuroChem and SUEK), Dmitry Alexandrovich PUMPYANSKY (associated with the Sinara group of companies) Dmitry Arkadievich MAZEPIN (related to Uralchem) and Vadim Nikolaevich MOSHKOVICH (related to Rusagro) seems particularly relevant from a business perspective (see also Consolidated list of sanctioned legal entities and persons).
Share
Insights
