On 13 March 2017, the Council of the European Union (EU) adopted Council Implementing Regulation (EU) 2017/437 and Council Decision 2017/445/CFSP extending the validity of sanctions (Restrictive Measures), including the asset freezing provisions (i.e. "blocking" measures) and travel bans which target certain Russian and Ukrainian individuals and entities. The Restrictive Measures, which were due to end on 15 March 2017, have been extended for a period of six months, until 15 September 2017.
The Restrictive Measures were originally imposed in 2014 by Council Regulation (EU) No 269/2014 and Council Decision 2014/145/CFSP (and were later extended by subsequent EU Council regulations and decisions), as a response to actions perceived by the European Union to undermine or threaten the territorial integrity, sovereignty and independence of Ukraine
According to the press release of the EU Council, "the assessment of the situation did not justify a change in the sanctions regime."
At present, the asset freezing provisions and travel bans remain applicable to 150 individuals and 37 entities.
It is three years since the EU imposed Restrictive Measures targeting Russia. In addition to those Restrictive Measures adopted pursuant to Council Regulation (EU) No 269/2014 and Council Decision 2014/145/CFSP , the EU currently imposes extensive sectorial sanctions against Russia and measures limiting trade with and investment in Crimea and Sevastopol. A decision on the extension of the latter categories of sanctions will be taken by the EU Council later this year.
With extensive prohibitions and restrictions remaining in place, EU and international companies doing business with Russian and Ukrainian partners should continue to exercise caution and undertake enhanced due diligence to ensure compliance with any applicable sanctions regulations.
Our global sanctions team, including dedicated experts located in Brussels, London and Washington DC, advises a wide range of European and other international clients on implementation of - and compliance with - sanctions targeting Russia, Crimea and Sevastopol as well as other sanctions regimes (including e.g. Iran, Syria, Lebanon, Sudan, Libya). To find out more, please contact the authors.