New sanctions announced by UK and EU on second anniversary of Russia’s invasion of Ukraine

To mark the second anniversary of Russia’s invasion of Ukraine on 24 February 2024, and in response to the death of Russian opposition leader Alexei Navalny in a Siberian penal colony on 16 February 2024, the UK and EU announced the approval of further sanctions against Russia. In the two years since the invasion, several sanctions packages have already been implemented, and you can read our Insights on the previous round of UK and EU sanctions, here and here.

As part of the most recent measures, the UK and EU, together with the U.S. and Japan, published an updated Common High Priority List. Comprising items considered integral to the development and maintenance of Russia’s weapons systems and armed forces, the Common High Priority List is intended to highlight to businesses the items that present an elevated risk of sanctions circumvention, and which are likely to be a priority for enforcement. First published in response to the Russia’s invasion of Ukraine, this list continues to be updated and expanded.

UK sanctions

Sanctions imposed in response to death of Navalny

On 21 February, the UK became the first country to impose sanctions in direct response to the death of Navalny. The Foreign, Commonwealth & Development Office (FCDO) announced asset freezes against the six individuals responsible for the operation of the IK-3 Arctic Penal Colony where Navalny died, including its head, Vadim Konstantinovich Kalinin. These asset freezes were imposed under the UK’s Global Human Rights Sanctions Regulations.

Sanctions imposed to mark the second anniversary of Russia’s invasion of Ukraine

On 22 February, the FCDO announced further measures as part of the UK’s wider sanctions regime against Russia, targeting 52 individuals and entities. These include oil and diamonds traders, manufacturers of munitions such as rocket launch systems, importers and manufacturers of machine tools (a reflection of their increasing importance in the development of defence systems components), and three Chinese companies found to have supplied restricted electronics to Russia’s military. 

This latest package also imposes a travel ban and asset freeze on Pavel Alekseevich Marinychev, CEO of PJSC Alrosa, the largest state-owned Russian diamond producer, which holds a 30% share in the global diamond market. This came only days before the implementation of the ban on the trade of Russian diamonds processed in third countries on 1 March 2024, with the UK updating its guidance to reflect that its general trade licence for such diamonds permits their import if they were already outside of Russia before 1 March and then processed outside of Russia (for more information, see our earlier post here). Other notable developments include the sanctioning of the Russian state-owned Sverdlov munitions plant, the largest plant in Russia’s ammunition industry, and entities based in Türkiye and the Marshall Islands.

EU sanctions

On 23 February, the EU approved its 13^th package of sanctions against Russia,  published in Council Regulation (EU) 2024/745 and Council Implementing Regulation (EU) 2024/753.

Asset freezes and travel bans

The EU’s latest package of sanctions comprises additional asset freezes against 194 entities and individuals, bringing the total number of persons designated by the EU under its Russia sanctions regime to 2,144 persons. Under EU sanctions, it is prohibited to make available, directly or indirectly, funds or economic resources to or for the benefit of designated persons or persons that are owned or controlled by designated persons.  Individuals covered by these measures are also subject to travel bans, preventing them from entering or transiting the EU.

Of the newly designated individuals and entities subject to asset freezes and travel bans:

• 140 operate within the Russian military industrial complex, generally working in the development of weapons systems, such as missiles, anti-aircraft systems and drones, as well as high-tech components for use in other military hardware.
• 17 have been involved in the kidnapping, forced transfer, deportation, and military indoctrination of Ukrainian children, including in Belarus.
• 16 are members of the judiciary or officials in occupied Ukraine.

With this latest sanctions package, the EU has also sought to target the transfer of weaponry and other military hardware to Russia, in particular from the Democratic People’s Republic of Korea (DPRK), by imposing restrictions on:

• Ten Russian entities and individuals responsible for the transport of weaponry, including shipping firms.
• The Defence Minister of the DPRK for their role in facilitating the transfer of military goods.
• Various entities and individuals based in Belarus, which have provided support to the Russian armed forces.

Trade measures

The EU has also added 27 entities to its list of parties deemed to support or form part of Russia’s military-industrial complex and which are subject to enhanced restrictions in connection with technology and dual-use items.  Notably, the EU has, for the first time, targeted Chinese and Indian companies which have supplied the Russian military with essential components and technologies. A number of the other entities targeted are located in Sri Lanka, Serbia, Kazakhstan, Thailand, and Turkey.

The EU’s latest package also broadens existing restrictions on technologies and electronics integral to Russia’s defence industry, to include components used for the development and production of drones, such as:

• Computer chips
• Ball bearings
• Electronic transformers
• Static converters
• Inductors
• Aluminium capacitors (which also have broader military applications in missiles and communication systems for aircrafts and ships)

Cameron Grabowski, Trainee, contributed to this article. 

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