Sanctions Updates of “Unfriendly” States

At the end of February 2024, a number of states taken the most restrictive measures against the Russian Federation prepared updates to their sanction’s legislation. The main changes are as follows.

US sanctions

The adoption of new sanctions was reflected in a significant expansion of the SDN-list1, including a number of financial institutions, companies whose activities are related to the military-industrial sector of the Russian Federation, as well as entities from third countries. In particular, JSC SUEK, JSC Mechel, NOVATEK-Murmansk, Ruskhimalliance, PJSC PIK Specialized Homebuilder (for the first time a developer company was included in the sanctions list), JSC Sovcomflot, Avangard Joint Stock Bank, Joint Stock Commercial Bank Modulbank, National Payment Card System Joint Stock Company fell under the sanctions.

At the same time OFAC published general licenses (№ 88А2, 893, 904, 91А5) authorizing operations aimed:

  • at terminating relations with entities subject to restrictive measures and companies controlled by them under the “50%” rule:
  • for vessels belonging to sanctioned persons – at ensuring safe docking and anchoring in port of blocked vessels, its emergency repairs, preservation of the safety of the crew, environmental mitigation or protection activities relating to any of the blocked vessels.

EU sanctions

The 13th sanctions package set the following restrictions6:

  • The list of goods prohibited for export in the Russian Federation has been expanded.

Now it also includes technological elements intended for the production of unmanned aerial vehicles, as well as other technologies and structures that can be used for military purposes.

  • Sanctions against Russian persons have been extended.

New sanctions mainly influence companies in the military-industrial complex. Among the new participants are JSC Krasnoye Znamya, JSC Sovfracht, JSC Leningrad Laser Systems, AviatestAero, heads of Russian logistics companies, companies from the military-industrial sector, and governors of a number of constituent entities of the Russian Federation.

  • The United Kingdom (in addition to Norway and Switzerland) has been included in the list of countries from which imports of ferrous metal goods do not require confirmation of the “non-Russian“ origin of raw materials.
  • Companies from third countries have been included in the sanctions lists as related to the Russian military-industrial complex.
  • Secondary sanctions have been imposed on a number of individuals – for importing prohibited goods as “parallel imports” and for supplying goods to manufacturers of military electronic products.

UK sanctions

The UK sanctions also affected individuals and legal entities7, including companies from both Russia and foreign countries. Among the participants of the updated sanctions list are diamond mining companies, shipping companies, Paramount Energy & Commodities SA, Arctic LNG 2, as well as a number of managers of sanctioned companies ALROSA and NOVATEK.

We continue to monitor the activity of “unfriendly” states in the adoption and application of the restrictive measures.

2 General license № 88А:
3 General license № 89:
4 General license № 90:
5 General license № 91А: