Ukraine/Russia

Information as of: 21st June 2017 

Latest Updates

 UN     
 US
 EU/UK  Russian sectoral sanctions extended until 31 Jul 2017 by EU 2016/2315/CFSP. EU 2014/119/CFSP, extended until 6 Mar 2018 by EU (CFSP) 2017/381. (EU) Council Decision (CFSP) 2017/445 renews asset freeze and travel ban until 15 September 2017. (CFSP) 2017/1087 renews until 23 June 2018 prohibitition on the import of goods originating in Crimea or Sevastopol, including related (re)insurance, unless granted a Certificate of Origin by the Government of Ukraine.

 

                                                                                                                                                                                                             

Financial/Other Sanctions

UN No
US EO 13660 (6 March 2014), updated by EO 13662 (20 March 2014)
EU/UK EU 208/2014 (6 March 2014), implemented by EU 269/2014 (17 March 2014) amended by EU 783/2014 (19 July 2014) and EU 810/2014 (25 Jul 2014). EU 2014/386/CFSP (23rd June 2014), amended by EU 825/2014 (31st July 2014), EU 1351/2014 (20 Dec 2014). EU 833/2014 (31st July 2014), EU 960/2014 (12th Sep 2014) both amended by EU 1290/2014 (5 Dec 2014). EU 2014/512.

 

                                                                                                                                                                                                             

Arms Embargo

UN No
US No. Currently operating a policy of denial for licences for arms and also in the process of revoking existing licences for defence articles and services. License requirement for dual-use goods, also currently operating a policy of denial for such military end use items.
EU/UK Council Reg 833/2014 effective 31st July 2014

 

                                                                                                                                                                                                             

Further Details

UN No
US EO 13660 blocking property of designated individuals/entities (including those entities that are owned or controlled by SDNs) by any 'US person' (effective 6 Mar 2014). Amended by EO 13661 (effective 17 Mar 2014) and EO 13662 (effective 20 Mar 2014) including further designations, including Bank Rossiya. Extended until 6 Mar 2017 under the National Emergencies Act. Sectorial Sanctions Identifications List, effective from 16 Jul 2014, includes a prohibition from transacting in, providing financing for, or otherwise dealing in debt of longer than 90 days’ maturity or new equity for certain Russian financial institutions and energy firms, their property or their interests in their property. Sectorial Sanctions expanded to further Russian banks and defence companies on 29 Jul 2014. Sectorial Sanctions expanded further to include more entities and a prohibition from transacting in, providing financing for, or otherwise dealing in debt of longer than 30 days maturity or new equity, their property or their interests in their property, for various persons named on SSI list, the provision, exportation, or re-exportation of goods, services or technology in support of exploration or production for deep water, Arctic offshore, or shale projects that have the potential to produce oil in the Russian Federation, or in maritime area claimed by the Russian Federation and extending from its territory, effective 12 Sep 2014. SDN List and General Licenses updated periodically. Ukraine Freedom Support Act 2014 signed into law on 18 Dec 2014 enables the imposition of additional measures from a number of options that can be imposed if warranted and includes sanctions against foreign financial institutions. Executive Order 19 Dec 2014 prohibits the import or export of any goods, services or technology to or from Crimea, the finance, guarantee or facilitation by a US person of any transaction by a foreign person that would otherwise be prohibited if performed by a US person, prohibition on purchasing any real estate or businesses in Crimea and the making of any new investment in Crimea. Several General Licences issued for certain activities and transactions. Entities added to the SDN list and Sectorial Sanctions list in Dec 2016 and issued general licence 11 in respect of certain transactions.
EU/UK Council Reg 208/2014 assets freeze for designations (wef 6 Mar 2014) effected by EU 269/2014 (wef 17 Mar 2014), amended by Council Reg 783/2014, (wef 19 Jul 2014), amends criteria for listing, updated periodically and (EU) Council Decision (CFSP) 2017/445 which renews asset freeze and travel ban until 15 September 2017. Council Decision 2014/386/CFSP effective 23 Jun 2014 prohibits the import of goods originating in Crimea or Sevastopol, including related (re)insurance, unless granted a Certificate of Origin by the Government of Ukraine,  renewed until 23 June 2018 by (CFSP) 2017/1087. Effective from 25 July 2014, EU Implementing Regulation 810/2014 lists further individuals and entities subject to sanctions and include the commercial seaports of both Kerch and Sevastopol. Council Reg 825/2014, effective 30 Jul 2014, includes a ban on finance and investment, including (re)insurance related to such transactions, in the sectors of transport, telecommunications and energy and the exploitation of natural resources in Crimea and Sevastopol and an export ban on key equipment and technology related to those sectors. Council Reg 833/2014 (wef 31 Jul 2014), includes a prohibition on EU nationals and companies buying or selling bonds, equity, or similar financial instruments with a maturity exceeding 90 days, issued by major state-owned Russian banks, development banks, their subsidiaries and those acting on their behalf (including services relating to the issuing of such financial instruments such as brokering); an arms embargo relating to the import and export of arms and related material from/to Russia. Also, a prohibition on the use of dual use goods and technology for military use in Russia or to Russian military end-users. Prohibition on the sale, supply, transfer or export of certain goods and technologies when destined for deep water/artic oil exploration and production or for shale oil projects and a prohibition to satisfy certain claims made by certain persons, entities and bodies. Reg 960/2014, (wef 12 Sep 2014), further restricts Russian access to EU capital markets by including a prohibition on EU nationals and companies buying or selling bonds, equity, or similar financial instruments with a maturity exceeding 30 days and also includes a prohibition on the provision of services for Russian deep water/artic oil exploration and production or for shale oil projects. Council Reg 1290/2014 (wef 5 Dec 2014) to clarify certain provisions in sanction measures. EU Commission issued a guidance note on 16 Dec 2014 to clarify the provisions issued in Jul 2014. Wef 20 Dec 2014, Reg 1351/2014 bans all foreign investment and associated services in Crimea or Sevastopol, services related to tourism including the maritime sector, prohibition on the sale, supply, transfer or export of goods in relation to transport, telecommunications, energy and the exploitation of oil, gas and minerals in Crimea and Sevastopol and ancillary services including direct or indirect financial services. EU published an FAQ on the implementation of its sanctions regime against Russia (October 2015). Russian sectoral sanctions added by EU 2014/512/CFSP to 31 Jul 2014 - extended until 31 Jul 2017 by EU 2016/2315/CFSP. (wef 20 Dec 2016). EU 2014/119/CFSP, extended until 6 Mar 2018 by EU (CFSP) 2017/381. SDN List updated periodically.

 

This information has been collated by the International Underwriting Association of London and is intended as a guide only. The IUA does not accept any liability for the accuracy of this information.
This publication is intended to convey only general information about sanctions legislation and associated insurance coverage. It is not, and is not intended to be, a complete statement of the law relating to this area. It should not be relied on or be used as a substitute for legal advice in relation to any particular set of circumstances. Accordingly, IUA does not accept any liability for any loss which may arise from reliance on this information.