European Sanctions Against Russia : Assets Freezes, Import and Export Ban, SWIFT

09 March 2022
Frédéric Saffroy and Alice Bastien

In support of Ukraine and although this may seem trivial in view of what Ukrainians are undergoing – and are likely to undergo – the European Council adopted strong economic, financial, and trade restrictive measures in response to the invasion of Ukraine by Russia. The different regulations adopted up to March 3, 2022 – directly applicable – tighten the sanctions taken in 2014 against Russia following the illegal annexation of Crimea.

The new restrictions, besides the symbolic ones [1], specifically target financial institutions, Russian elites, state-owned companies, and several of Russia’s critical industries and sectors such as energy, transport, telecommunications, aviation and high-tech.

To fight the Russian disinformation campaign, the Council also prohibited Russia Today and Sputnik, two state-owned media, to broadcast in the European Union [2].

New sanctions may be implemented soon and could target crypto assets. At the same time, Europe provides help to Ukraine and Ukrainians [3].

Lastly, measures have also been taken by the United States, the United Kingdom, Canada, Australia and Japan.

1. Asset Freezes

All funds and economic resources belonging to any natural persons, or natural or legal persons associated with them, are frozen [4]. It includes funds or economic resources made available, directly or indirectly, to those natural persons.

As of March 3rd, 2022, 680 people and 53 entities, including the president Vladimir Putin, are subject to an asset freeze because of their affiliation with the State of Duma or because of their ties with the Russian government [5].

The same restrictive measures apply to Belarusian persons associated with the Lukashenko regime [6].

2. Import, Export, and Dual-Use Goods

Initially concerning goods and technology intended for military use or for a military end-user only [7], the prohibition to sell, supply, transfer or export dual-use goods and technology to any natural or legal person in Russia or for use in Russia extends from now on to any use. There is also an export ban on all goods and technologies used in the defence and security sector, in the oil refining process and in the aviation or space industry [8].

Dual-use goods and technology export in Belarus or for use in Belarus is also prohibited [9].

The import of goods originating from the areas of the Donetsk and Luhansk oblasts is forbidden. By derogation, trade contracts concluded before February 23, 2022, may be executed until May 24, 2022. In addition, there is an export ban on goods and technologies suited for use in the sectors of transport, telecommunications, energy and production of oil, gas, and mineral resources [10].

3. Investment and SWIFT

After prohibiting the purchase, sell, or deal with transferable securities and money-market instruments issued by Russia, its government, the Central Bank of Russia, any entities acting on behalf of the Central Bank [11], or issued by legal persons and entities established in Russia with over 50% public ownership or control [12], the Council banned the investment, participation or contribution to projects co-financed by the Russian Direct Investment Fund [13].

As of March 12, 2022, it will be prohibited to provide specialised financial messaging services, which are used to exchange financial data (SWIFT), to seven banks (Otkritie, Novikombank, Promsvyazbank, Rossiya Bank, Sovcombank, Vnesheconombank (VEB), and VTB Bank) or to any legal person or entity established in Russia whose proprietary rights are directly or indirectly owned for more than 50 % by one of the bank listed [14].

For any additional information, please contact the Compliance and Regulatory team

Frédéric Saffroy, Partner & Alice Bastien, Associate


[1] A ban on the overflight of EU airspace by Regulation (EU) 2022/334 of 28 February 2022 and a suspension on the issuance of visas by Decision (EU) 2022/333 of 25 February 2022.

[2] Regulation (EU) 2022/350 of 1 March 2022.

[3] Provision of equipment and supplies to the Ukrainian Armed Forces through the European Peace
Facility, EUR 500 million support package to finance the Ukrainian Armed Forces, humanitarian aid and EUR 1,2 billion financial aid (Decision (EU) 2022/313 of 24 February 2022).

[4] Annex I of the Council Regulation (EU) 269/2019 of 17 March 2014, consolidated, set forth the list of the persons and entities concerned by the asset freezes.

[5] Regulation (EU) 2022/260 of 23 February 2022, Regulation (EU) 2022/261 of 23 February 2022, Regulation (EU) 2022/332 of 25 February 2022, Regulation (EU) 2022/336 of 28 February 2022.

[6] Regulation (EU) 2022/300 of 24 February 2022, Regulation (EU) 2022/353 of 2 March 2022.

[7] Regulation (EU) 833/2014 of 31 July 2014.

[8] Regulation (EU) 2022/328 of 25 February 2022.

[9] Regulation (EU) 2022/355 of 2 March 2022

[10] Regulation (EU) 2022/263 of 23 February 2022.

[11] Regulation (EU) 2022/262 of 23 February 2022.

[12] Regulation (EU) 2022/328 of 25 February 2022.

[13] Regulation (EU) 2022/345 of 1 March 2022.

[14] Regulation (EU) 2022/345 of 1 March 2022.