In light of the current conflict and crisis in Ukraine, we are tracking the evolving sanctions imposed by several governments on Russia and Russia-aligned regions and certain individuals. The jurisdictions in focus are: EU, Japan, Republic of Korea, UK and US.
US – April 21, 2022: President Biden issued a proclamation prohibiting Russian-affiliated vessels from entering US ports. Under the proclamation a “Russian-affiliated vessel” means:
- Vessels under Russian registry, i.e. Russian flagged vessels;
- Russian-owned vessels, i.e. the Russian government or a Russian company, citizen or permanent resident appears as the legal title owner on the vessel’s registration documents; or
- Russian-operated vessels, i.e. a Russian company, citizen or permanent resident makes “the commercial decisions” regarding the employment of a ship, including how and where the vessel is employed.
There are two exceptions to the prohibition.
- The prohibition does not apply to Russian-affiliated vessels “used in the transport of source material, special nuclear material, and nuclear byproduct material” for which and for as long as it is determined “no viable source of supply is available” without the use of such Russian-affiliated vessels.
- Additionally, the prohibition does not apply to Russian-affiliated vessels seeking to enter a US port “due to force majeure, solely to allow seafarers of any nationality to disembark or embark for purposes of conducting crew changes, emergency medical care, or for other humanitarian need.”
The prohibition is effective April 28, 2022.
Also on April 21, BIS issued a TDO, suspending the export privileges of Russian airline Aviastar for violating US export controls. The agency issued the 180-day TDO for the cargo aircraft carrier, which BIS noted, will limit the airline’s ability to deliver goods to Russia’s military, Under the TDO, Aviastar will be barred from participating in transactions with items subject to the Export Administration Regulations.
See complete tracker for US.
EU – April 21, 2022: The EU added additional parties to its Russian sanctions regime. The additions include businessmen Serhiy Vitaliyovich Kurchenko and Yevgeniy Viktorovich Prigozhin. Kurchenko took control of various metallurgical, chemical and energy plants in the separatist-held areas of Crimea, and Prigozhin founded and serves as the unofficial leader of the Russian-based mercenary entity the Wagner Group.
See complete tracker for EU.
Japan –April 20, 2022:Japan officially enacted a law that revokes Russia’s most favored nation status. The change, which takes effect later in April, allows Japan to impose higher duties on most imports from Russia; however, the change will not impact imports of oil and liquefied natural gas.
See complete tracker for Japan.
UK – April 22, 2022: The UK Government announced further trade restrictions on a range of Russian Generals and defense firms.
See complete tracker for UK.
Please contact us with any questions.