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Updated EU Sanctions in response to Russia’s invasion of Ukraine

  • Latvia

    01-03-2022

     

    The sanctions package of 28 February 2022. Aviation and Finance.

     The most recent Eversheds Sutherland update memorandum on continued expansion of sanctions against Russia can be accessed here.

     The situation is constantly developing. As a matter of update, on 28 February 2022, the Council of the European Union (Council) adopted Decision (CFSP) 2022/335 amending Decision 2014/512/CFSP concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine. Therefore, the initial Regulation regarding Russia’s invasion of Ukraine - (EU) 833/2014 regulation concerning restrictive measures in view of Russia's actions destabilising the situation in Ukraine was amended, and Council has adopted Regulation 2022/334.

     The latest set of sanctions contains severe restrictive measures (sanctions) related to aviation and finance.

     

    AVIATION

    According to Regulation 2022/334, it is prohibited as from Monday, 28 February 2022, to land intake off from, or overfly, the territory of the EU for:

    • Russian air carriers, including as a marketing carrier in code-sharing or blocked-space arrangements;
    • any Russian-registered aircraft;
    • any non-Russian-registered aircraft owned, chartered, or otherwise controlled by any Russian natural or legal person, entity, or body.

    Exception! The restriction mentioned above will not apply to:

    • emergency landings; 
    • emergency overflights;
    • situations when the competent authorities have authorised an aircraft to land in, take off from, or overfly the territory of EU if the competent authorities have determined that such landing, take-off, or overflight is required for humanitarian purposes or any other purpose consistent with the objectives of this Regulation No 833/2014 (the notice about any authorisation granted must be given to the Member States and the Commission within two weeks of such authorisation).

     

    FINANCE

    The new regulations also prohibit transactions with the Central Bank of Russia. This means that it is forbidden to carry out:

    • transactions related to the management of reserves of the Central Bank of Russia;
    • transactions related to the management of assets of the Central Bank of Russia;
    • transactions with any legal person, entity, or body acting on behalf of, or at the direction of, the Central Bank of Russia.

    Exception!

    The restriction mentioned above will not apply in situations when authorities authorize a transaction, provided that it is strictly necessary to ensure the financial stability of the EU as a whole or the Member State concerned (the Member States and the Commission must be informed immediately of Members States intentions to grant such authorization).

     

    PERSONS AND ENTITIES

     Additionally, given the gravity of the situation, on 28 February 2022, the Council implemented new Regulation (EU) 2022/336, amending Annex I to Regulation (EU) No 269/2014. In these amendments, 26 new persons and one entity have been added to the list of persons, entities, and bodies subject to restrictive measures set out in Annex I to Regulation (EU) No 269/2014.