Russia: new restrictive measures imposed by USA and EU

4 January 2024

Here are the latest updates on the sanctions imposed by the United States and the European Union against Russia.

United States

 On December 22, 2023, US President Biden issued the Executive Order 14114 (“Taking Additional Steps With Respect to the Russian Federation’s Harmful Activities”) amending the existing E.O. (Executive Orders) targeting certain sectors of the Russian economy in the light of the ongoing war against Ukraine, i.e E.O. 14024 of 15 April 2021 (“Blocking Property With Respect To Specified Harmful Foreign Activities of the Government of the Russian Federation”) and E.O. 14068 of 11 March 2022 (“Prohibiting Certain Imports, Exports, and New Investment With Respect to Continued Russian Federation Aggression”).

The E.O. of 22 December granted the US Treasury Department additional authority to impose sanctions on foreign financial institutions that directly or indirectly assist Russia’s military-industrial base.

Amendments to the E.O. 14024

In particular, the new amendment to E.O. 14024 authorises the imposition of US sanctions (“secondary sanctions”) on foreign financial institutions upon determining that the foreign financial institution:

  1. has conducted or facilitated any significant transaction on behalf of persons designated to operate or have operated in the following key sectors of the Russian economy supporting the country’s military-industrial base: technology, defence and related materials, construction, aerospace, manufacturing or other sectors which the Treasury considers to be part of the military-industrial base; or
  2. has conducted or facilitated any significant transaction or provide services involving the Russian military-industrial base, including the sale, supply or transfer, directly or indirectly, to Russia of items identified by the Treasury.

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