Russia/Ukraine Sanctions Update – Month Of September – Export Controls & Trade & Investment Sanctions

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I. US SANCTIONS

  • OFAC Makes Russia-related Designations to Its SDN
    List:
    On September 14, 2023, the Departments of State and
    the Department of the Treasury imposed further sanctions on over
    150 individuals and entities, including five Turkish firms and one
    Turkish individual, in connection with Russia’s unlawful
    invasion of Ukraine. The Departments targeted individuals and
    entities including Russia’s elites, industrial base, financial
    institutions, technology suppliers, and those engaged in sanctions
    evasion and circumvention, those complicit in furthering
    Russia’s ability to wage war against Ukraine, and those
    responsible for bolstering Russia’s future energy production.
    Read more >>
  • OFAC Issues Russia-related General Licenses:
    On September 14, OFAC issued General License 55A, “Authorizing
    Certain Services Related to Sakhalin-2” and General License
    72, “Authorizing the Wind Down of Transactions Involving
    Certain Entities Blocked on September 14, 2023.” General
    License 55A allows for importation of Sakhalin-2, previously
    prohibited by OFAC starting November 21, 2022, into Japan through
    June 28, 2024. General License 72 authorizes the wind down of
    transactions involving eight companies sanctioned by OFAC on
    September 14, 2023. This wind down period will last through
    December 13, 2023. The license does not authorize any transactions
    prohibited by Directive 2 under E.O. 14024, Directive 4 under E.O.
    14024, or any transaction otherwise prohibited by the RuHSR.
    Read more >>
  • US Department of State Announces Additional Sanctions
    on Russian Energy Production:
    On September 14, 2023, the
    US State Department imposed sanctions on over 70 entities and
    individuals involved in expanding Russia’s energy production
    and export capacity, operating in Russia’s metals and mining
    sectors and aiding Russian individuals and entities in evading
    international sanctions. The Department of State also designated
    one Russian Intelligence Services officer and one Georgian-Russian
    oligarch. Read more >>
  • US Department of Commerce Targets 28 Companies from
    China, Russia, and Other Countries:
    On September 25, 2023,
    the Department of Commerce’s Bureau of Industry and Security
    (BIS) targeted 28 companies from China, Russia and other countries
    for conspiracy to violate US export controls and other activities
    contrary to US national security interests. The new designations
    included nine firms implicated in violating existing export
    controls through a scheme to supply a Russian company with
    components to build unmanned aerial vehicles for Russia’s
    intelligence agency. Read more >>
  • US and UK Sanction Additional Members of the
    Russia-based Trickbot Cybercrime Gang:
    On September 7,
    2023, the US, in coordination with the UK, sanctioned eleven
    individuals who are part of the Russia-based Trickbot cybercrime
    group. The Trickbot group has ties to Russian intelligence services
    and has targeted the US government and US companies, including
    hospitals. Read more >>Also on September 7,
    2023, the Department of Justice indicted multiple Russian
    cybercrime actors involved in the Trickbot malware and ransomware
    schemes. Read more >>
  • OFAC Sanctions Five Entities and Two Individuals for
    Supplying Components for Unmanned Aerial Vehicles Used by Russia
    Military in Ukraine:
    On September 27, 2023, OFAC
    sanctioned five entities and two individuals based in Iran, the
    People’s Republic of China, Hong Kong, Turkey, and the United
    Arab Emirates involved in the procurement of sensitive parts for
    Iran’s one-way attack unmanned aerial vehicle (UAV) program.
    This network has facilitated shipments and financial transactions
    in support of the Islamic Revolutionary Guard Corps Aerospace Force
    Self Sufficiency Jihad Organization’s procurement of
    servomotors, a critical component used in Iran’s Shahed-series
    UAVs. Iran has been supplying Russia with Shahed-136 UAVs to
    support Russia’s illegal invasion of Ukraine. Read more >>
  • Deputy Secretary of the Treasury Convenes REPO Deputies
    Meeting:
    On September 7, 2023, the Deputy Secretary of the
    Treasury and Principal Associate Deputy Attorney General convened a
    Russian Elites, Proxies, and Oligarchs (REPO) Deputies meeting. At
    the meeting, participants from Australia, Canada, the European
    Commission, France, Germany, Japan, Italy, the United Kingdom, and
    the United States discussed ongoing sanctions enforcement
    initiatives and noted the need to counter Russian elites and their
    proxy networks that continue to enable and profit from Putin’s
    war economy. REPO members committed to taking steps to fully map
    Russian sovereign assets and ensure that Russian assets held in
    REPO member jurisdictions will remain immobilized until Russia pays
    for the damage it has caused to Ukraine. Read more >>
  • US Department of Commerce Meets with International
    Allies and Adds Important Updates to Its List of Controlled
    “Common High Priority” Items:
    On September 19,
    2023, the Department of Commerce’s Bureau of Industry and
    Security (BIS) met with the UK, EU, and Japan to continue
    coordination in response to Russia’s invasion of Ukraine. As a
    result, BIS added seven new Harmonized System codes to its
    “common high priority” items list, including bearings
    needed for heavy vehicles or other machinery and antennae used for
    navigation systems. Read more >>
  • Secretary of State Suggests Asset Transfer from Russian
    Oligarchs to Ukraine Occurring:
    During a September 6 press
    availability with Ukrainian Foreign Minister Dmytro Kuleba,
    Secretary of State Antony Blinken stated that the US, “for the
    first time,” is transferring assets seized from sanctioned
    Russian oligarchs to Ukraine to support Ukrainian military
    veterans. Read more >>
  • BIS Issues Guidance to Prevent High Priority Items from
    Being Diverted to Russia:
    On September 28, the Department
    of Commerce’s Bureau of Industry and Security (BIS) issued a
    new guidance document for US industry to prevent high priority
    items from being shipped to Russia. The guidance recommends that
    exporters secure written confirmation from their customers to help
    prevent diversion, and provides a sample written attestation for
    this purpose. Read more >>
  • US Defense Secretary Announces Ukrainian Forces Will
    Soon Receive US Abrams Tanks:
    During his opening remarks
    at the 15th Ukraine Defense Contact Group on September
    19, 2023, the Secretary of Defense, Lloyd J. Austin, announced that
    the M1 Abrams tanks that the US had previously committed to
    “will be entering Ukraine soon.” The Defense Secretary
    also highlighted that the US has committed additional
    security-assistance packages totalling more than $2 billion. These
    packages include urgently needed air defense, ammunition, and
    mine-clearing equipment. Read more >>
  • DOJ Arrests Russian International Money Launderer for
    Defrauding the United States:
    On September 18, 2023, DOJ
    charged Maxim Marchenko, a Russian citizen, in connection with
    conspiring to defraud the United States and smuggling, wire fraud,
    and money laundering offenses. Marchenko is alleged to have
    participated in a scheme to unlawfully procure US-sources, dual-use
    microelectronics with military application on behalf of end users
    in Russia. Read more >>
  • Miami-based Businessman Pleads Guilty to Conspiracy to
    Violate Russia-Ukraine Sanctions:
    On September 13, 2023,
    Sergey Karpushkin, a Miami resident and citizen of Belarus, plead
    guilty to engaging in a scheme to violate US sanctions and commit
    money laundering by conducting transactions for the purchase and
    acquisition of metal products valued at over $139 million from
    companies owned by Sergey Kurchenko, an OFAC-designated SDN.
    Karpushkin also agreed to forfeit over $4.7 million in criminal
    proceeds. Read more >>
  • US Department of Commerce Issues Temporary Denial Order
    in Support of Strike Force Case:
    On August 31, 2023, the
    Department of Commerce’s Bureau of Industry and Security issued
    a temporary denial order (TDO), suspending the export privileges of
    three individuals – Arthur Petrov, Zhanna Soldatenkova, and Ruslan
    Almetov – and four companies – Astrafteros Technokosmos LTD, Ultra
    Trade Service LLC, Juzhoi Electronic LLC, and LLC Electrocom VPK –
    all of which are part of a Russia-based illicit procurement network
    that supplies the Russian military. Read more >>
  • US Sanctions Authorities Delay KFC’s Russia
    Exit:
    KFC’s exit from Russia was delayed after OFAC
    issued a compliance guidance to the industry regarding the Russia
    “exit tax,” while negotiations on the exit deal were
    ongoing. The delay illustrates how corporate exits have become more
    complicated as Russia has tightened its restrictions. Read more >>

II. EU SANCTIONS

  • EU’s General Court Dismissed the Actions Brought by
    Mr. Dmitry Alexandrovich Pumpyanskiy and Ms. Galina Evgenyevna
    Pumpyanskaya Against EU Sanctions:
    On September 6, the
    General Court dismissed the actions brought by Mr. Pumpyanskiy and
    his wife. The General Court held that although Mr. Pumpyanskiy has
    not played a direct role in military offensive in Ukraine, he is
    involved in economic sectors which constitute a substantial source
    of revenue for the Government of Russia. Read more >>and Read more >>
  • EU’s General Court Dismissed the Action Brought by
    Ms. Elena Petrovna Timchenko Against EU Sanctions:
    On
    September 6, the General Court dismissed the action brought by Ms.
    Timchenko highlighting amongst others involvement of Ms. Timchenko
    within the Timchenko Foundation associated with her husband.
    Read more >>
  • EU’s General Court Decided that EU Sanctions on
    Aleksandr Aleksandrovich Shulgin Should Be Lifted:
    On
    September 6, the General Court ruled that sanctions against Mr.
    Shulgin should be lifted recalling the need for an updated
    assessment of the grounds for sanctions. Read more >>
  • EU’s General Court Dismissed the Action Brought by
    Mr. Tigran Khudaverdyan against EU Sanctions:
    On September
    6, the General Court dismissed the action brought by Mr.
    Khudaverdyan. Read more >>
  • EU’s General Court Dismissed the Action Brought by
    Mr. Mikail Safarbekovich Gutseriev against EU Sanctions:

    On September 6, the General Court dismissed the action brought by
    Mr. Gutseriev. Read more >>
  • Commission Published Guidance to Help European
    Operators Assess Sanctions Circumvention Risks:
    On
    September 7, the European Commission published a guidance note
    addressed to European operators to help them identify, assess, and
    understand the possible risks of sanctions circumvention and how to
    avoid it. This guidance note aims at providing a general overview
    of what EU operators need to do when conducting due diligence in
    their work, as required by EU law. Read more >>
  • EU Sanctioned Six Individuals for Human Rights
    Violations in Russia and Ukraine:
    On September 8, the EU
    decided to impose restrictive measures on six individuals
    responsible for human rights violations in Russia and Ukraine,
    including violations of freedom of opinion and expression. The
    individuals listed include prosecutors and judges active in courts
    established by Russia’s occupying force in illegally annexed
    Crimea, as well as members of the Russian Federal Security Service.
    Read more >>and Read more >>
  • European Parliament Note on Recent Publications and
    Commentaries from Think Tanks on Russia’s War on
    Ukraine:
    On September 8, the European Parliamentary
    Research Service published its regular update note gathering links
    to the recent publications and commentaries from international
    think tanks on Russia’s war on Ukraine. Read more >>
  • European Commission Has Updated Its Russia Sanctions
    FAQs on Imports, Purchase and Transfer of Listed Goods:
    On
    September 12, the European Commission updated its FAQ regarding
    personal goods and vehicles temporarily brought by Russian
    nationals. Read more >>
  • EU Individual Sanctions against Russia Prolonged for
    Further Six Months:
    On September 13, the EU decided to
    prolong the individual sanctions targeting those responsible for
    undermining or threatening the territorial integrity, sovereignty,
    and independence of Ukraine until March 15, 2024. The sanctions
    measures provide for travel restrictions for natural persons, the
    freezing of assets, and a ban on making funds or other economic
    resources available to the listed individuals and entities.
    Sanctions will continue to apply to almost 1,800 individuals and
    entities altogether. Read more >>
  • Three Russian Individuals Removed from the EU Sanctions
    List:
    On September 13, the EU removed Aleksandr
    Aleksandrovich Shulgin, Grigory Viktorovich Berezkin and Farkhad
    Akhmedov from the sanctions list in the context of the EU sanctions
    renewal. Read more >>and Read more >>
  • EU’s General Court Dismissed the Action Brought by
    Mr. Alexander Evgenevich Shatrov against EU Sanctions:
    On
    September 13, the General Court dismissed the action brought by Mr.
    Shatrov against EU sanctions in view of the situation in Belarus.
    Read more >>
  • EU’s General Court Dismissed the Action Brought by
    Mr. Viktor Filippovich Rashnikov against EU Sanctions:
    On
    September 13, the General Court dismissed the action brought by Mr.
    Rashnikov against EU sanctions in respect of actions undermining or
    threatening the territorial integrity, sovereignty and independence
    of Ukraine. Read more >>
  • EU’s General Court Dismissed the Action Brought by
    Synesis TAA against EU Sanctions:
    On September 13, the
    General Court dismissed the action brought by a Belarusian company
    active in the sector of information technology Synesis TAA against
    EU sanctions in view of the situation in Belarus. Read more >>
  • Action Brought by Mr. Vladimir Gheorghe Plahotniuc
    against EU Sanctions:
    On September 25, the EU published
    information on the action brought on August 9, 2023, by Mr.
    Plahotniuc against EU sanctions in view of actions destabilizing
    the Republic of Moldova. Read more >>
  • Glencore Traded Russian Copper through Turkey:
    It is reported that commodity trading company Glencore brought at
    least 5,000 tons of Russian copper sheets made by Russia’s Ural
    Mining and Metallurgical Company (UMMC) routed through Turkey to
    Italy in July 2023. It is estimated that overall Turkish imports of
    copper cathode and wire rod were 125,000 tons higher year on year
    in the first six months of 2023, and far in excess of domestic
    requirements. Read more >>
  • European Commission Clarifies That ‘No-Claims
    Clause’ Protects Operators Complying with EU
    Sanctions:
    On September 27, the European Commission
    explained that a ‘no-claims clause’ included as a standard
    provision in EU sanctions legislations protects operators required
    to comply with EU sanctions from having to satisfy claims of any
    type brought forward by certain third parties, whenever those
    claims are connected with the performance of a contract or
    transaction affected by EU sanctions. This includes claims for
    indemnity or any legal claim for compensation. Read more >>and Read more >>
  • European Commission Confirms That No Derogation Allows
    for The Transfer of Banknotes to Russia:
    On September 27,
    the European Commission reaffirmed that there is no derogation to
    the prohibition to sell, supply, transfer, or export to Russia of
    banknotes denominated in any official currency of a Member State or
    to any natural or legal person, entity or body in Russia or for any
    use in Russia. Member States are responsible for the implementation
    of EU sanctions and must take the necessary measures to make sure
    that sanctions are applied, including by carrying out
    investigations. Read more >>and Read more >>

III. UK SANCTIONS

  • UK and EU Russia-connected Iron and Steel Ban to Come
    into Force:
    On September 30, 2023, the Russia-connected
    iron and steel bans announced by the UK and EU will come into force
    prohibiting the import of iron and steel products from third
    countries which originate from Russia or are processed from Russian
    iron and steel. Companies are also required to provide evidence
    that this is not the case. UK Department for Business & Trade
    and Department for International Trade published guidance on the
    measures earlier this month, providing examples of what would/would
    not be prohibited. Read more >>
  • OFSI Amends One UK Sanctions Designation: On
    September 27, 2023, OFSI amended one entry in the UK Sanctions
    List. The entry for Alexei Kozlov was updated, and he remains
    subject to an asset freeze and trust services sanctions. Read more >>
  • UK, along with E5 nations, Issues Joint Guidance on
    Countering Russian Evasion of Export Controls:
    On
    September 26, 2023, the E5 issued joint guidance to industry and
    academia identifying high priority items critical to Russian
    weapons systems and urging specific actions to prevent diversion of
    these items to Russia through third countries. The guidance
    provides a list of 45 prioritised Harmonised System (HS) codes
    containing items Russia needs for its weapons systems. The guidance
    then identifies patterns associated with importers in non-GECC
    (Global Export Control Coalition) countries that may raise (i)
    diversion concerns, (ii) due diligence tips for screening such
    parties, and (iii) red flag indicators that may be relevant to
    exporters to assist in determining whether an activity may be
    connected to export control and/or sanctions evasion. Read more >>and Read more >>
  • OFSI Issues General Licence for Payments to Water
    Companies:
    On September 21, 2023, OFSI issued General
    Licence INT/2023/3179120, which permits, among other things, any
    person designated under UK autonomous sanctions regulations to pay
    water companies for water and sewage services, subject to certain
    conditions. Read more >>
  • UK Government Updates High Priority Items
    Lists:
    On September 21, 2023, the UK’s FCDO updated
    its list of controlled “common high priority” items (i.e.
    items identified as critical to Russia’s war effort) by (i)
    adding 7 new product codes, including bearings needed for heavy
    vehicles or other machinery and antennae used for navigation
    systems and (ii) dividing Tier 3 of the list into mechanical and
    non-mechanical items. Read more >>
  • OFSI Updates 4 Russian Sanctions Designations:
    On September 19, 2023, OFSI amended one and corrected three entries
    in the UK Sanctions List. The entries for the following individuals
    were updated: (i) Mikhail Maratovic Fridman, (ii) Zarakh
    Binsionovich Iliev, (iii) Igor Viktorovich Makarov and (iv)
    Iskander Kakhramonovich Makhmudov. All of these individuals remain
    subject to an asset freeze and trust services sanctions. Read more >>
  • UK, along with Other G7 nations, to Introduce Russia
    Diamonds Import Ban:
    On September 18, 2023, a Belgian
    official announced that a ban on imports of Russian diamonds is
    expected to be agreed by the G7 in the next two or three weeks.
    According to the official, there would be a direct ban on purchases
    from 1 January 2024 as well as an indirect ban, which would be
    phased in over time. Earlier in 2023, the UK Prime Minister banned
    the import of Russian diamonds, copper, aluminium, and nickel. Read more >>and Read more >>
  • UK Government Proscribes Wagner Group as Terrorist
    Organization:
    On September 15, 2023, the UK Government
    proscribed the Wagner Group as a terrorist organisation. Actively
    supporting and/or belonging to the Wagner Group is now a criminal
    offence that could be punished by imprisonment of up to 14 years
    and/or a fine. Read more >>
  • The UK and US Extend Sakhalin-2 Project Sanctions
    Exemption:
    On September 14, 2023, the UK Government
    amended General Licence INT/2022/2470156 to extend the exemption of
    oil originating in or consigned from Sakhalin-2 from the oil price
    cap until 28 June 2024. The relevant part of the General License
    authorises the supply or delivery of Russian oil (and the provision
    of related services) originating in or consigned from Sakhalin-2
    from a place in Russia to a place in Japan. Read more >>and Read more >>
  • UK Lords Committee Calls for Evidence on UK-EU
    Cooperation on Sanctions for Inquiry:
    On September 12,
    2023, the UK House of Lords European Affairs Committee launched an
    inquiry into the long-term implications for the UK of the EU’s
    foreign and security policy response to the Russian invasion of
    Ukraine, including UK-EU cooperation on sanctions, and their
    enforcement and effectiveness. The Committee has issued a call for
    evidence, inviting interested individuals and organisations to
    submit written evidence to the inquiry by 27 October 2023. The
    Committee encourages anyone with expertise in or experience of the
    matters under consideration in its inquiry to submit written
    evidence. Read more >>and Read more >>
  • UK Government Provides Guidance on Russian Iron and
    Steel Processed in Third Countries:
    On September 8, 2023,
    the UK Government published guidance on the scope of the measures
    related to Russian iron and steel processed in third countries
    (which will come into force on 30 September 2023). The notice sets
    out inter alia: (i) what evidence traders need to provide
    to demonstrate compliance; (ii) what constitutes an “iron and
    steel” product; (iii) examples of how the rules may be applied
    in practice; and (iv) corresponding licensing provisions. Read more >>
  • UK Sanctions 11 Members of the Russia-based Trickbot
    Cybercrime Gang:
    On September 7, 2023, OFSI added 11
    individuals to the UK sanctions list in a coordinated effort with
    the United States. The individuals are connected to the Russian
    cyber criminal gang behind the Trickbot/Conti ransomware attacks
    that targeted hospitals and other critical infrastructure during
    the Covid-19 Pandemic. Those sanctioned have been targeted with
    asset freezes and travel bans by UK authorities to counter the
    threat of ransomware both in the UK and abroad. The National Crime
    Agency (NCA), who conducted a complex investigation into these
    individuals, assesses that the group was responsible for extorting
    at least $180 million from victims globally, and at least £27
    million from 149 UK victims. Read more >>and Read more >>
  • FCA Publishes Review of the Sanctions Systems of
    Financial Services Firms:
    On September 7, 2023, the UK
    Financial Conduct Authority published a review of the sanctions
    systems and controls in place in over 90 financial services firms.
    The review found that (i) there were good practices, such as firms
    who conducted risk exposure assessments in advance of the Russian
    invasion of Ukraine, and firms who conducted sample testing and
    tuning, (ii) governance and oversight needed to be improved in many
    firms, there was an over-reliance on third party sanctions
    screening tools, and in some global firms, global policies were not
    aligned with the UK sanctions regime, (iii) many firms had
    significant backlogs in the assessment of alerts from sanctions
    screening, some firms had inadequate internal expertise, and some
    firms had inadequate screening capabilities, and (iv) there were
    low quality Customer Due Diligence and Know your Customer
    assessments and inconsistencies in reporting breaches to the FCA.
    Read more >>
  • UK Says It Will Declare Russia’s Wagner Group a
    Banned Terrorist Organisation:
    On September 6, 2023, Great
    Britain announced that it will declare Russia’s Wagner
    mercenary group a banned terrorist organization, saying it remains
    a threat to global security even after the death of leader Yevgeny
    Prigozhin. The government said an order will be introduced in
    Parliament to proscribe the group under the Terrorism Act. The
    designation, once approved by lawmakers, will bar membership in or
    support for Wagner, which has played a major fighting role in
    Russia’s invasion of Ukraine. It has also operated in Syria and
    several African countries. The ban will allow UK authorities to
    seize the organization’s assets, though that power is largely
    symbolic as Wagner is not known to operate in Britain. The move
    follows a recommendation by Parliament’s influential Foreign
    Affairs Committee in July that Wagner be outlawed. The committee
    said British authorities had “underplayed and
    underestimated” the threat posed by the mercenary group. Read more >>

IV. RUSSIA/UKRAINE SANCTIONS

  • Russia Dodges G7 Price Cap Sanctions on Most of Its Oil
    Exports:
    Russia has succeeded in avoiding G7 sanctions on
    most of its oil exports, a shift in trade flows that will boost the
    Kremlin’s revenues as crude rises towards $100 a barrel. Almost
    three-quarters of all seaborne Russian crude flows travelled
    without western insurance in August, a lever used to enforce the
    G7’s $60-a-barrel oil price cap. The rise implies that Moscow
    is becoming more adept at circumventing the cap, allowing it to
    sell more of its oil at prices closer to international market
    rates. Read more >>
  • Putin Extends 2014 Anti-Sanctions Measure Until the End
    of Next Year:
    Russian President Vladimir Putin extended
    the decree on response measures to Western sanctions until December
    31, 2024. The new decree extends the duration of the food embargo
    introduced in 2014. These restrictions were a response to Western
    sanctions imposed after the annexation of Crimea to Russia, and
    covers beef, pork, poultry, fish, seafood, cheeses, milk, fruits,
    vegetables, etc. Read more >>
  • Russia Bans Entry to 23 British Individuals:
    On September 27, 2023, the Russian Ministry of Foreign Affairs
    added 23 British individuals to its “stop list”, banning
    their entry into Russia. The full list of names was not published,
    but the individuals are members of the UK’s military,
    political, media, and academic communities, and certain individuals
    were named, including: (i) Chief of the Defence Staff, Admiral Sir
    Tony Radakin, (ii) Madeleine Alessandri, chair of the Joint
    Intelligence Committee, and (iii) Cressida Hogg, chair of British
    defence contractor BAE Systems. Read more >>
  • Russia Suspends Fuel Exports Amid Shortages:
    On September 21, 2023, Russia announced that it had suspended
    exports of gasoline and diesel fuel to curb price hikes during
    harvest season amid reports of gasoline shortages in the
    country’s southern regions. The government’s press service
    stated that the move was a “temporary measure” in order
    to stabilise domestic prices. Fuel prices had risen due to high
    prices on world markets, devaluation of the rouble and a sharp
    reduction in the fuel damper by the government. Read more >>
  • Putin Extends Gas Price Limit for Gazprom’s Joint
    Venture with Wintershall and ÖMV:
    Russian President
    Vladimir Putin extended until October 1, 2024, a decree prohibiting
    Gazprom from buying gas from joint ventures with the German
    Wintershall Dea and the Austrian ÖMV above the fixed maximum
    price. The initial description began to operate on March 1, 2022.
    Read more >>
  • Russian Central Bank Extends Restrictions on Transfers
    of Non-Residents from “Unfriendly” Countries:

    Transfers abroad of funds of non-residents – both individuals and
    legal entities – from unfriendly countries from the accounts of
    brokers and trustees will be limited from October 1 for another six
    months, according to an order of the Central Bank of Russia. The
    regulator emphasized that the decision was made to maintain
    financial stability. On April 1, 2022, the Bank of Russia limited
    the transfers abroad of funds of non-resident individuals and legal
    entities from unfriendly countries from the accounts of Russian
    brokers. Read more >>
  • Kremlin Has Blocked 18 Billion Dollars in Profits of
    Companies from “Unfriendly” Countries:
    Western
    companies that have continued to operate in Russia since
    Moscow’s full-scale invasion of Ukraine have generated billions
    of dollars in profits, but the Kremlin has blocked them from
    accessing the cash in an effort to turn the screw on
    “unfriendly” nations. Groups from such countries
    accounted for $18bn of the $20bn in Russian profits that overseas
    companies reported for 2022 alone. Local earnings of companies have
    been locked in Russia since the imposition last year of a dividend
    payout ban on businesses from “unfriendly” countries
    including the US, UK and all EU members. While such transactions
    can be approved under exceptional circumstances, few withdrawal
    permits have been issued. Read more >>
  • Russia Raises Interest Rates to 13% Amid Inflation
    Concerns:
    Russia’s Central Bank raised interest rates
    from 12% to 13% on Friday as it said it remains concerned about an
    inflationary spiral taking hold across the Russian economy. The
    move is the second rate hike in two months following an emergency
    meeting in August held after the Russian ruble fell below 100
    against the US dollar. The ruble has since dipped just below the
    crucial level — seen as a barometer of economic health by
    many Russians — but has failed to strengthen significantly. A
    falling currency pushes up the price of goods that use imported
    parts. Meanwhile, record labor shortages are driving wages higher,
    which also adds to price concerns. Read more >>
  • State Property Fund of Ukraine Issues a Register of
    Sanctioned Assets:
    The Digital Transformation Office of
    the State Property Fund has launched a website that contains a list
    of all seized assets of Russians and collaborators that have been
    transferred to the Fund’s management. The register contains
    information on 136 sanctioned assets and is available at the
    following link: www.sanlist.spfu.gov.ua. Read more >>
  • Ukraine Confiscated the Property of 28 Sanctioned
    Persons in One Year:
    The Supreme Anti-corruption Court of
    Ukraine transferred property of 28 natural and legal persons
    subject to sanctions to the state possession between 1 September
    2022 and 1 September 2023. During the year, the Ministry of Justice
    of Ukraine filed 29 lawsuits for the recovery of assets into the
    state’s possession, 28 of them were satisfied (in the first
    instance). 25 of the adopted decisions have already entered into
    legal force, the rest are either under appeal or at the stage of
    entry into force. Read more >>
  • Aeroflot Settles Dispute with an Irish Lessor over 18
    Aircraft:
    The Russian airline Aeroflot has completed a
    settlement of the dispute with the Irish company AerCap regarding
    18 aircraft that were leased from it. Ownership of the aircraft and
    engines passed to NSK Insurance Company LLC, which paid the amount
    for the aircraft to settle the dispute. The company’s press
    service clarified that they continue negotiations with other
    lessors to resolve disputes regarding other aircraft. Read more >>
  • Moscow Court Declines to Hear US Reporter
    Gershkovich’s New Appeal against Detention:
    On
    September 19, 2023, Moscow City Court declined to hear US reporter
    Evan Gershkovich’s latest appeal against his pre-trial
    detention on spying charges, sending it back to the Lefortovo
    district court citing procedural violations. Gershkovich, a
    reporter for the Wall Street Journal, was arrested on March 29,
    2023, in the Urals city of Yekaterinburg on charges of espionage
    that carry up to 20 years in prison. No date has been set for his
    trial, and in August, 2023, his detention in Moscow’s Lefortovo
    prison was extended by three months to November 30. Read more >>
  • Ukraine’s Zelenskyy Vetoes New Asset Declaration
    Bill Amid Ongoing Struggle against Graft:
    On September 12,
    2023, Ukrainian President Volodymyr Zelenskyy vetoed legislation
    that allowed officials to continue not disclosing their assets, as
    Kyiv struggles to clamp down on corruption and assure allies that
    it’s committed to fighting graft. The announcement came days
    after Zelenskyy pushed out his defense minister and shuffled
    several other top officials amid growing concerns that corruption
    and embezzlement have continued despite the ongoing Russian
    invasion. Read more >>

V. OTHER NOTABLE DEVELOPMENTS

  • Canada Imposes 63 Sanctions against Russia Individuals
    and Entities:
    On September 22, 2023, Canadian Prime
    Minister, Justin Trudeau, announced 63 sanctions against Russian
    individuals and legal entities during Ukrainian President Volodymyr
    Zelensky’s visit to Canada. The individuals and entities were
    involved in the illegal movement and detention of Ukrainian
    children, the generation and dissemination of disinformation and
    propaganda, as well as the nuclear programs of the Russian
    federation. Read more >>
  • Australia Backs International Court Action against
    Russia:
    On September 21, 2023, Australia’s
    solicitor-general, Stephen Donaghue, made an appearance at the
    International Court of Justice to argue the Court has jurisdiction
    to hear a case against Russia for its “illegal and
    immoral” invasion of Ukraine. The case involves Ukraine’s
    claim that alleges Russia violated the Convention on the Prevention
    and Punishment of the Crime of Genocide, to which both Ukraine and
    Russia are parties. Read more >>
  • South Korea, Japan, and US Agree to Take Stern Measures
    against Potential Arms Deal Between Russia and North
    Korea:
    On September 22, 2023, Seoul’s Foreign
    Minister, Park Jin, US Secretary, Anthony Blinken, and Japanese
    Foreign Minister, Yoko Kamikawa, met to express deep concerns over
    Russia and North Korea’s military cooperation and agreed to
    respond firmly to any acts that threaten regional security in
    violation of the U.N. Security Council resolution. Read more >>
  • Kazakhstan Promises to Follow Sanctions Regime against
    Russia:
    Kazakhstan “will definitely follow” the
    sanctions regime against Russia, President of the Republic
    Kassym-Jomart Tokayev said at a press conference after negotiations
    with German Chancellor Olaf Scholz. Since April of this year,
    Kazakhstan began to require the issuance of accompanying invoices
    for goods when trading with EAEU countries. The measure was taken
    to prevent circumvention of anti-Russian sanctions and limit
    parallel imports. Read more >>
  • Trudeau Pledges Canada’s Support for Ukraine and
    Punishment for Russia:
    On September 23, 2023, Canada’s
    Prime Minister, Justin Trudeau, announced several support measures
    for Ukraine including military, economic, and humanitarian
    assistance. Canada’s pledge to stand with Ukraine will include
    $650 million in new military assistance over the next three years.
    This assistance will include providing Ukraine with 50 armoured
    vehicles, pilot and maintenance instructors for F-16 fighter jets,
    support for Leopard 2 battle tank maintenance, 35 drones with
    high-resolution cameras, light vehicles, and ammunition. Canada and
    Ukraine also agreed to establish a working group with G7 partners
    to study seizure and forfeiture of Russian assets, including those
    from the Russian Central Bank. Read more >>
  • Japan Commits to Complying with US Sanctions Despite
    Energy Concerns:
    On September 19, 2023, Japan’s Chief
    Cabinet Secretary, Hirokazu Matsuno, confirmed that Japan will
    ensure a stable and steady energy supply while complying with US
    sanctions related to Russia’s Artic LNG 2 Project, where
    Mitsui, a Japanese Trading Company, and JOGMEC, a state-owned Japan
    organization, were set to receive a combined 2 million metric tons
    of liquefied natural gas per year from the Russian project. Read more >>
  • International Criminal Court Opens Field Office in Kyiv
    to Track Russian War Crimes:
    On September 14, 2023,
    Ukrainian Prosecutor-General’s Office announced that the
    International Criminal Court (ICC) had opened a field office in
    Kyiv as part of efforts to hold Russian forces accountable for
    potential war crimes committed during its invasion of Ukraine. The
    office in the Ukrainian capital is the ICC’s largest outside of
    The Hague and has opened after it has been reported that more than
    104,000 war crimes had been registered during Russia’s
    aggression against Ukraine. Read more >>
  • Kim Tells Putin That Russia Has North Korea’s
    ‘Full and Unconditional Support’:
    On September 13,
    2023, Russian President Vladimir Putin held talks with North Korean
    leader Kim Jong Un, who offered his country’s “full and
    unconditional support” to defend what he said was Russia’s
    security interests, in an apparent reference to Russia’s
    invasion of Ukraine. Putin showed Kim around Russia’s most
    advanced space rocket launch site in Russia’s Far East and
    discussed the possibility of sending a North Korean cosmonaut into
    space. Read more >>and Read more >>

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