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Competition Law

Analysis - debate - current awareness

Field Fisher Waterhouse , 05 SEP 2014


John Cassels


With the situation in Ukraine fluctuating between bad and terrible, what are the sanctions that the EU has imposed to try to curb Russian agitation?

They comprise three key elements:

  • Restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine. These sanctions are directed at specified individuals and companies (primarily those with links to President Putin) and comprise freezing of funds and economic resources and a general prohibition on making funds available to those parties. 

  • Restrictive measures in response to the annexation of Crimea and Sevastopol. There is an import ban on goods originating in Crimea and Sevastopol and a prohibition on related financing and insurance services. 

  • Restrictive measures in view of Russia's actions destabilising the situation in Ukraine. This involves an expansion of previously imposed sanctions which prohibit and/or limit the sale, supply or export of military or dual-use goods and technologies for the oil industry to persons in Russia or for use in Russia. There are also specific restrictions on purchasing, selling or providing brokerage services for securities or money market instruments issued by certain Russian banks. 

Fines can be imposed on companies engaging in business activities with sanctioned parties. Breaches of the rules also generally result in a loss of export privileges and reputational damage. Those engaging in business that might be affected by the sanctions must undertake enhanced due diligence checks and keep the issue under review (as of this morning, 5 September, EU Member States are considering a new package of proposed sanctions against Russia).

If you are interested in these issues, please do not hesitate to contact John Cassels at john.cassels@fieldfisher.com
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