Morgan Lewis US and Russia Sanctions Update
Basic Framework - US/EU/UK (cont'd)
European Union
EU Council Reg. No. 833/2014 of 31 July 2014 - as amended and (several times, most recently by Reg. No.
2019/1163
of 5 July 2019)
Applies to EU nationals and companies
Or anything happening in whole or part within EU territory
Or involving an EU-registered aircraft / vessel
Currently in effect to 31 July 2021 (extended as of 27 Dec. 2020)
Commission Guidance Note (16 Dec. 2014, last amended 25 Aug. 2017) on application of certain provisions
(the "EU Guidance Note")
And SDN-like "blacklist" Reg. No. 269/2014 of 17 March 2014
And updates since then (incl. re the Siemens turbines scandal and re the Kerch bridge - see slides 82-83)
Currently in effect to 15 Sept. 2021 (most recently extended on 12 March 2021)
And, re Crimea
-
EU Council Reg. No. 692/2014 of 23 June 2014 - as amended by Reg. No. 825/2014 of 30 July 2014, and
Reg. No. 1351/2014 of 19 Dec. 2014 (last extended on 18 June 2020 now in effect to 23 June 2021)
Hits investments in oil & gas and other mineral resources E&P, power, transport, telecoms
And further ban on business in various other sectors - see slide 82 for detail
EU Council Reg. No. 2018/1542 of 15 Oct. 2018, Concerning Restrictive Measures Against Proliferation and
Use of Chemical Weapons; and implementing measures naming Russians as violators (incl. most recent - slide 12)
And Dec. 2020 enactment of EU Global Human Rights Sanctions Regime - and March 2021 first application,
against Russian officials in connection with Navalny detention etc. - see slide 12
Post-Brexit UK: see slides 84-85
Morgan Lewis
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