Sanctions’ nature

Spheres (individuals) affected

1st wave

March 2014

Suspension of collaboration with the Russian Federation in certain spheres

• Defense complex;
• Investment construction;
• Space exploration

 Approval of lists with individuals on which the “personal” sanctions are imposed, including:

• Ban on entering the USA and EU countries;
• Freeze on foreign assets;
• Ban for residents of the USA and EU countries on entering into any contractual relations with the persons affected by sanctions

Certain Russian and Crimean officials “responsible for destabilization of the situation in Ukraine,” in particular: S.M. Mironov, A.A. Klishas, S.V. Aksenov, V.A. Konstantinov, V.Yu. Surkov.

2nd wave

March 2014

–

July 2014

Periodic expansion of the lists of individuals subject to “personal” sanctions

• Russian and Crimean officials;
• Military;
• Businessmen, “people close to V.V. Putin” (Arkady and Boris Rotenberg, Gennady Timchenko and Vladimir Yakunin) and organizations “maintaining interests of chief executive officers of Russia” (Rossiya Bank and its group of entities, Sobinbank, Volga Group, Transoil, etc.)

3rd wave

July 2014

–

August 2014

Introducing “sectoral” sanctions.

 USA:

• Restriction on equipment supply for mining operations in Russia;
• Restriction on financing certain banks of the Russian Federation with state participation and their property for a period over 90 days

 EU:

• Sanctions related to Crimea (ban on investments in certain industries; on purchasing over 250 types of goods; issue of loans, purchasing shares in projects related to “sectoral” sanctions);
• Embargo on import and export of weapons; ban on export to Russia (for Russian customers) of dual use goods, and technologies for military use;
• Ban on transactions with primary securities and instruments of currency market in relation to Russian banks with state participation;
• Establishment of authorization procedure for export of certain equipment and technologies of energy service purpose into the Russian Federation;
• Including Dobrolet airline (subsidiary of Aeroflot) in the sanctions lists with regard to servicing Moscow-Simferopol flights

• Financial sector;
• Oil and gas sector;
• Energy service sector;
• Defense industry;
• Civil aviation.

Responsive sanctions of Russia

March 2014

–

August 2014

“Personal” and “sectoral” sanctions:

•  Certain officials of EU, USA and Canada are prohibited from entering the Russian Federation (additionally, the list of individuals in relation to which the sanctions are imposed was approved; it is not subject to public disclosure);
• Russia announced a ban on transit flights of Ukrainian airlines though the Russian air space as a responsive sanction to EU’s sanctions against Dobrolet airline.
• Ban on import of agricultural products:

-   On August 06, 2014 import of agricultural products (meat and dairy products, fish, vegetables, fruits and nuts), whose country of origin introduced economic sanctions in relation to Russian legal entities and/or individuals, is prohibited in the Russian Federation;

-   On August 20, 2014 for the benefit of diabetics and persons with allergies and the entrepreneurs dependent on import of production materials the following products are excluded from the list of banned goods: delactosed milk and milk products; nutritional supplements; vitamin-mineral complexes; flavors; protein concentrates (animal and vegetable) and their mixes; dietary fibers and food supplements (including complex); alevins of Atlantic salmon and trout; certain species of inocula.

• Agriculture;
• International trade;
• Civil aviation.

  Igor Gorokhov
  Senior Associate

  Saint-Petersburg
  Тел.: +7 (812) 346 79 90