The EU, the US and the UK Have Consistently Imposed Economic Restrictions on Their Own Citizens

04 April 2022
Ellina Izotkina
Associate
Anzhelika Kalashyan
Legal Trainee

The purpose of the economic restrictions imposed in February-April 2022 is officially declared to be “changing Russia’s behavior” and exerting “pressure” on those involved in the events in Ukraine. To this end, restrictions were imposed on various sectors of the Russian economy, as well as on citizens of the Russian Federation.

Prior to the new “packages” of economic restrictions in 2022, citizens of “unfriendly states” were not included in the SDN lists by the respective states. The situation is gradually changing: now the EU, the US and the UK citizens and companies are under attack.

1. The EU sanctions 

The European Union was the first to impose sanctions against its own citizens.

According to Council Implementing Regulation (EU) 2022/336 of February 28, 20221 Mr. Gennady Timchenko (citizenships: Russian, Armenian, Finnish) and Mr. Petr Aven (citizenships: Russian, Latvian) fell under economic restrictions.

Following them, sanctions were imposed on Roman Abramovich (citizenship: Russia, Portugal), in accordance with the Council Implementing Regulation (EU) 2022/427 of March 15, 20222.  Portugal confirmed3 that they would not cease Mr. Abramovich citizenship, nor they would ban him from entering the country, since there is no legal framework for EU countries on establishing such restrictions and applying them to EU citizens. 

2. The US sanctions 

On March 31, 20224, three companies registered in the UK and Spain and one individual (a British citizen) with “connections” with these companies were added to the SDN list.

The website of the American government5 contains a detailed scheme according to which these persons, according to US data, carried out transactions with Russian companies. 

3. The UK sanctions 

Companies established in the UK and included in the US sanctions lists also fell under the blocking sanctions of the UK on March 31, 20226. The assets of the companies are subject to freezing.

1 https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=OJ:L:2022:058:FULL&from=EN
2 https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32022R0427&qid=1649060081038&a...
3 https://www.reuters.com/world/europe/portugal-change-law-that-allowed-abramovich-get-citizenship-min...; https://www.reuters.com/world/europe/portugal-says-sanctions-against-abramovich-do-not-apply-outside...
4 https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20220331
5 https://home.treasury.gov/news/press-releases/jy0692
6https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1065...