Category Archives: Russia sanctions

Russia sanctions

01.15.16
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Notice to Exporters 2016/03: Russian sanctions extended till 31 July

ECO Notice to Exporters 2014/22 outlined the EU economic sanctions introduced in response to Russia’s destabilising role in Eastern Ukraine. The measures were contained in Council Decision 2014/512/CFSP, and the 22 June 2015 amendment to the Council Decision linked the restrictive measures to the complete implementation of the Minsk agreements.

On 21 December 2015, the EU Council extended the economic sanctions on the basis that the Minsk agreements would not be completely implemented by 31 December 2015.

The new amendment extends the restrictive measures until 31 July 2016, to enable the Council to further assess the implementation of the Minsk agreements.

As a reminder to exporters, the restrictive measures include:

    • An arms embargo.
    • A prohibition on supply of dual-use items which are or may be intended for military end-use or for a military end-user in Russia.
    • Requirement of an export licence for the export of certain energy-related equipment and technology to Russia (or any other country if such equipment or technology is for use in Russia).

Link:

Notice to Exporters 2016/03

 

12.14.15
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Notice to Exporters 2015/28 – Hydrazine export to Russia now restricted

Hydrazine and related compounds (the Notice mentions monomethyl hydrazine and unsymmetrical dimethyl hydrazine) can be used as rocket propellant, so now any transactions in these chemicals now requires authorization). This change is encapsulated in the Export Control (Russia, Crimea and Sevastopol Sanctions) (Amendment) Order 2015, which amends the 2014 Order.

Fun fact: ECO included a footnote directing readers who wanted more detail on hydrazine and its uses to Chambers Dictionary of Science and Technology.

Links:

Notice to Exporters 2015/28

Export Control (Russia, Crimea and Sevastopol Sanctions) (Amendment) Order 2015

Export Control (Russia, Crimea and Sevastopol Sanctions) Order 2014

ECO Russian sanctions FAQ

 

03.31.15
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All together now: Expanded DFAT sanctions on Russia, Crimea, Sevastopol start

Expanded Australian sanctions were initially announced on September 1st of last year, but weren't in force until today. They include the following restricted activities:

    • the export to and import from Russia of arms and related materiel;
    • the export to Russia of specified items for use in petroleum exploration and production;
    • the export to Crimea and Sevastopol of specified items for use in the energy and minerals sector;
    • commercial dealing with certain capital financial market instruments issued by certain Russian state-owned entities; and
    • Australian investment in Crimea and Sevastopol related to infrastructure, transport, telecommunications, energy, oil, gas and minerals sectors.

For individuals and firms with existing legal obligations that run afoul of the restrictions, they can apply for authorization on the Online Sanctions Administration System (OSAS).

DFAT has also released the public consultation report on these expanded sanctions.

As for the title of the post, the notice states that the expanded sanctions “closely match” those of the EU, US and Canada. Makes the boat go faster when all the oars all pull the same direction at the same speed..

Links:

DFAT Sanctions: Crimea and Sevastopol, Russia, Ukraine

Online Sanctions Administration System

Public Consultation Report

 

11.24.14
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November 18, 2014: Australia telegraphs its upcoming punch

On Tuesday, the Department of Foreign Affairs and Trade (DFAT) submitted the following proposed changes to the sanctions against Russia for comment:

Restrictions on the supply, sale or transfer of goods

The amending regulation would prohibit the unauthorised supply, sale or transfer of the following ‘export sanctioned goods’ for Russia, Crimea and Sevastopol:

Russia
      • arms or related materiel
      • Australian Obligated Nuclear Material
      • equipment and technology for use in deep water oil exploration or production in Russia, Arctic oil exploration or production in Russia, or a shale oil project in Russia, as specified in the Autonomous Sanctions (Russia, Crimea and Sevastopol) Specification 2014;
Crimea and Sevastopol
      • equipment and technology relating to the creation, acquisition or development of infrastructure in the transport, telecommunications and energy sectors and the exploitation of oil, gas and mineral reserves in Crimea and Sevastopol, as specified in the Autonomous Sanctions (Russia, Crimea and Sevastopol) Specification 2014;
Restrictions on the import, purchase or transport of goods

The amending regulation would prohibit the unauthorised import, purchase or transport of the following ‘import sanctioned goods’ for Russia, Crimea and Sevastopol:

Russia
Crimea and Sevastopol
      • all goods exported from Crimea and Sevastopol
Restrictions on the export or provision of services

The amending regulation would prohibit the unauthorised provision of the following ‘sanctioned services’ for Russia, Crimea and Sevastopol:

Russia

the provision to Russia, or a person for use in Russia, of technical advice, assistance or training, or financial assistance, or financial service, or another service, if it assists with, or is provided in relation to:

      • a military activity
      • the manufacture, maintenance or use of arms or related materiel or Australian Obligated Nuclear Material
      • engagement in a sanctioned commercial activity for Russia

the provision to Russia, or to a person, entity or body for use in Russia, the following services necessary for deep water oil exploration or production in Russia, Arctic oil exploration or production in Russia, or a shale oil project in Russia:

      • drilling
      • well-testing
      • logging and completion services
      • supply of specialised floating vessels
Crimea and Sevastopol

the provision to Crimea or Sevastopol, or a person for use in Crimea or Sevastopol, of technical advice, assistance or training, or financial assistance, or financial service, or another service, if it assists with, or is provided in relation to:

      • the manufacture, maintenance or use of an ‘export sanctioned good’ for Crimea or Sevastopol
      • engagement in a ‘sanctioned commercial activity’ for Crimea or Sevastopol
Restrictions on commercial activities

The amending regulation would prohibit the unauthorised engagement in the following ‘sanctioned commercial activities’ for Russia, Crimea and Sevastopol:

Russia
      • the direct or indirect purchase or sale of, or any other dealing with, bonds, equity, transferable securities, money market instruments or other similar financial instruments, if the financial instrument is issued by Russian state-owned banks, entities involved in military supplies and services and entities selling or transporting crude oil and petroleum products, specified in the Autonomous Sanctions (Russia, Crimea and Sevastopol) Specification 2014 and has a maturity period exceeding thirty days, as specified in the Autonomous Sanctions (Russia, Crimea and Sevastopol) Specification 2014;
Crimea and Sevastopol
      • the granting of any financial loan or credit, or the establishment of a joint venture, relating to the creation, acquisition or development of infrastructure in the transport, telecommunications or energy sectors and the exploitation of oil or gas, or of mineral reserves, in Crimea and Sevastopol, as specified in the Autonomous Sanctions (Russia, Crimea and Sevastopol) Specification 2014;
      • the acquisition or extension of an interest in an enterprise established in Crimea or Sevastopol and is engaged in the creation, acquisition or development of infrastructure in the transport, telecommunications or energy sectors and the exploitation of oil or gas, or of specified mineral reserves, in Crimea and Sevastopol.

The comment period ends on December 9th.

Link:

DFAT Public Consultation page

 

08.15.14
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Notice to Exporters 2014/24: Russia, Syria, South Sudan, Libya updates

In this NTE (Notice to Exporters), Russia is now a prohibited destination under the following licenses:

In addition, two changes were made to the Category C Goods and Small Arms and Light Weapons licenses above:

  • South Sudan is now a non-permitted destination
  • Russia, Libya and Syria are now specifically mentioned under point 1 of Schedule 2

Links:

Notice to Exporters 2014/24

 

08.06.14
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Notice to Exporters 2014/22: New EU Russia Sanctions

Just a recap of the new export restrictions placed on Russia by the EU. The highlights:

    • An arms embargo. The UK interprets the arms embargo as applying to all items on the UK Military List. There are related prohibitions on the provision of technical assistance, financing and financial assistance, and brokering services. The embargo also bans the purchase, import or transport of military goods from Russia.
    • A prohibition on supply of dual-use items which are or may be intended for military end-use or for a military end-user in Russia. There are also related prohibitions on the provision of technical assistance, financing and financial assistance, and brokering services. These prohibitions do not apply to items intended for civil end-use and civil end-users. Export licence applications for items intended for purely civil end-use will continue to be assessed on a case-by-case basis in the usual way.
    • An export licence will be required for the export of certain energy-related equipment and technology to Russia (or any other country if such equipment or technology is for use in Russia). The goods and technologies affected are listed in Annex II to Council Regulation 833/2014. A licence will not be granted if there are reasonable grounds to determine that the export is for projects pertaining to deep water oil exploration and production, Arctic oil exploration and production, or shale oil projects in Russia. Further information on these new measures is provided below.

And some FAQ-style info from the Notice:

Do these sanctions prohibit all engagement in the Russian shale, arctic and deep water sectors?

There are restrictions on the provision of technical assistance, brokering services and financing and financial services relating to the identified technologies. While the Government can give general advice and guidance about the scope of these new restrictions and how to comply with them, we cannot give legal advice – companies requiring legal advice should make their own arrangements.

Links:

Notice to Exporters 2014/22

Council Decision 2014/512/CFSP

Council Regulation (EU) No 833/2014