March 11, 2022

EU imposes additional sanctions upon Belarus and Russia

The European Commission and the European Council announced the imposition of additional sanctions on March 9, 2022 in response to the unprovoked aggression against Ukraine by Russia with the assistance of Belarus.  The new measures were implemented upon the Council’s adoption of Council Regulation (EU) 2022/398 and Council Decision (CFSP) 2022/399 to address the actions by Belarus, and the adoption of Council Regulation (EU) 2022/394 and Council Decision (CFSP) 2022/395 to address the actions by Russia.   

According to the Commission, the goal of the new Belarus-related sanctions was to more closely align the sanctions upon Belarus with those imposed upon Russia in order to ensure that Russian sanctions could not be circumvented by transacting through Belarus. To that end, the Council imposed restrictions on the provision of specialized financial messaging services (SWIFT) to Belagroprombank, Bank Dabrabyt, the Development Bank of the Republic of Belarus, and their Belarusian subsidiaries, and prohibited transactions with the Central Bank of Belarus related to the management of reserves or assets and the provision of public financing for trades and investments involving Belarus.  The EU also placed significant limitations on financial inflows from Belarus by prohibiting the acceptance of deposits that exceed €100,000 from Belarusian residents and prohibiting EU central securities depositories from holding the accounts of Belarusian clients and selling euro-denominated securities to Belarusian clients.  The Council also announced that will prohibit the listing and provision of services in relation to shares of Belarus state-owned entities on EU trading venues as of April 12, 2022.

The new Russian sanctions included restrictions on the export of maritime navigation and radio communications technology to Russia and, among other things, added the Russian Maritime Register of Shipping to the list of state-owned entities subject to financing limitation.  The Council also clarified that the notion of “transferable securities” includes crypto-assets in an effort to ensure the proper implementation of restrictions already in place.  Sanctions were also imposed upon 160 additional individuals who participated in actions that undermined or threatened the territorial integrity, sovereignty of Ukraine.  Among the newly-listed individuals were 14 oligarchs and prominent Russian businesspeople (and their families) and 146 members of the Russian Federation Council.

European Commission Press Release | European Council Press Release I | European Council Press Release II | Council Regulation (EU) 2022/394 and Council Decision (CFSP) 2022/399 | Council Regulation (EU) 2022/398 and Council Decision (CFSP) 2022/399