Industrial Policy & Trade Monitor· 2667 actions· ✨ 89 recent

On 16 December 2022 the Council of the European Union adopted Council Regulation (EU) 2022/2474, the 9th package of restrictive measures against Russia, amending Regulation (EU) 833/2014. It entered into force on publication the following day (17 December 2022). The package extends the prohibition on new EU investment from the Russian energy sector to the Russian mining and quarrying sector, bans exports of aircraft and drone engines and their parts to Russia (and to any third country that could re-supply drones to Russia), adds 168 entities to the sectoral export- control annex covering chemicals, nerve agents, night-vision and radio- navigation equipment, electronics and IT components, and prohibits EU advertising, market-research, product-testing and technical-inspection services to Russia. A parallel Council Decision/Implementing Regulation designated a further 141 individuals and 49 entities to the EU asset-freeze and travel-ban list.

Switzerland's Federal Council amended the Ordinance on measures in connection with the situation in Ukraine (SR 946.231.176.72) to align with the EU's eighth sanctions package, effective 6pm on 23 November 2022. The amendment creates the Swiss legal basis for an oil price-cap mechanism — banning maritime transport to third countries of Russian-origin crude oil and petroleum products unless purchased at or below a price cap to be set later (the G7/EU $60/bbl cap followed on 3 December 2022; see the companion US OFAC determination of 2022-12-05). It also extends import/export restrictions to additional iron and steel products and aerospace goods, bans the provision of IT, engineering, architecture and legal services to the Russian government and Russian companies, bans Swiss nationals from holding board seats at certain Russian state-owned companies, fully bans crypto-asset wallet/account/custody services to Russian persons regardless of value, and adopts an arms embargo against Russia (extended in part to Ukraine for reasons of Swiss neutrality).

On 19 October 2022, the US Treasury's Office of Foreign Assets Control (OFAC) designated Russian national Yury Yuryevich Orekhov, resident in Dubai, UAE, under Executive Order 14024 for operating a network that procured military and sensitive dual-use technology from Western suppliers for Russian end-users. Two entities tied to Orekhov were designated alongside him: NDA Nord-Deutsche Industrieanlagenbau GmbH, based in Hamburg, Germany, and Opus Energy Trading LLC, based in Dubai, UAE. The designation blocks all US property and interests of the designated persons and generally prohibits US persons from transacting with them.

On 6 October 2022 the Council of the European Union adopted Council Regulation (EU) 2022/1904, amending Regulation (EU) No 833/2014, as the EU's eighth package of restrictive measures against Russia. It entered into force 7 October 2022. The regulation's headline measure creates the legal basis for an oil price-cap mechanism: a ban on maritime transport to third countries of Russian-origin crude oil and petroleum products, becoming operational once the Council sets an actual cap level by a separate decision (the G7/EU $60/bbl cap followed on 3 December 2022). The package also expands import bans on steel products (phased through 2024), firearms and ammunition, wood pulp and paper, and certain chemicals, cosmetics and jewellery materials; extends export bans on aviation-sector goods; bans the provision of architectural, engineering, IT-consultancy and legal advisory services to the Russian government and Russian companies; and imposes restrictions on Russian-flagged vessels at the Russian Maritime Register.

Canada registered SOR/2022-98, Regulations Amending the Special Economic Measures (Russia) Regulations, on 6 May 2022, adding five Russian defence-sector entities to Schedule 1 of the regulations: Zelenodolsk Shipyard JSC, Military Industrial Company LLC, Rosgvardia, UEC Klimov JSC and KAMAZ PTC. The listing triggers Canada's standard dealing/asset-freeze prohibitions against the named entities under the Special Economic Measures Act, part of Canada's ongoing sanctions response to Russia's February 2022 invasion of Ukraine.

On 2 May 2022 OFAC published a comprehensive final rule in the Federal Register renaming the Ukraine Related Sanctions Regulations (31 CFR Part 589) to the Ukraine-/Russia-Related Sanctions Regulations and replacing the abbreviated regulatory text that had been in place since 2014 with a fully elaborated framework. The new Part 589 incorporates interpretive guidance, definitional provisions, and consolidated general licenses implementing Executive Orders 13660, 13661, and 13662 — the original March 2014 Ukraine/Crimea-crisis authorities. The rule does not introduce new substantive prohibitions; it formalises and makes accessible the regulatory infrastructure that underlies subsequent GL issuances (e.g., GL 13Q/13R, GL 15K/15L) and OFAC designation actions under the Ukraine-/Russia-Related Sanctions program.

Regulations Amending the Special Economic Measures (Belarus) Regulations, SOR/2022-49, were registered and came into force on 8 March 2022. They add 19 individuals and 25 entities to Schedule 1 and widen the listing criteria to cover persons supporting the violation of Ukraine's sovereignty or territorial integrity. Listed entities named in the regulatory impact statement include the potash producer Belaruskali OAO and the Belarusian Potash Company, the Naftan Oil Refinery and Belneftkhim, and Absolutbank, Belinvestbank, Belbizneslizing and Bank Dabrabyt. Listing brings asset freezes and dealing prohibitions for persons in Canada.

On 4 March 2022 Switzerland's Federal Council adopted a total revision of the Ordinance on Measures Relating to the Situation in Ukraine (SR 946.231.176.72), taking effect the same day at 18:00, to fully implement the EU's sanctions packages of 23 and 25 February 2022. The revision bans export of all dual-use goods to Russia regardless of end use or end user, bans export of goods that could contribute to Russia's military or technological strengthening or its defence and security sector, and prohibits export of specified goods and services to the oil sector, as well as goods for aviation, space and oil-refining/gas-liquefaction use.

On 1 March 2022 Japan's Foreign Minister announced a second package of sanctions over Russia's military action in Ukraine. It suspended visas for and froze assets of designated Russia-related individuals and entities, froze the assets of three Russian banks (VEB.RF, Promsvyazbank, Bank Rossiya), and imposed export restrictions on Russian military-related entities and on controlled items on internationally agreed lists and other dual-use goods such as semiconductors. Relevant ministries were to proceed with the domestic implementing procedures.

On 1 March 2022, OFAC published an interim final rule adding the Russian Harmful Foreign Activities Sanctions Regulations (RuHSR) at 31 CFR Part 587, codifying into Title 31 of the Code of Federal Regulations all prohibitions previously imposed by Executive Order 14024 of 15 April 2021. The regulations were issued in abbreviated form to provide immediate public guidance, with OFAC indicating an intent to supplement them with additional definitions, general licenses, and interpretive guidance. All transactions prohibited under EO 14024 — including prior sectoral determinations and directives targeting Russia's financial services sector, sovereign debt markets, and key state institutions — are formally prohibited under Part 587, giving domestic courts and compliance teams a stable regulatory anchor.

On 24 February 2022 (25 February NZ time) the New Zealand Government announced its first measures after Russia's invasion of Ukraine: targeted travel bans on Russian Government officials and individuals associated with the invasion, a prohibition on exporting goods to Russian military and security forces, and suspension of bilateral foreign-ministry consultations. The export prohibition is end-user based; the announcement does not itemise products or give a trade value. GTA tags cereals, vegetables and fruit-and-nuts sectors for this intervention; the primary release reviewed does not mention them.

On 24 February 2022, hours after Russia's invasion of Ukraine began, the UK Foreign Secretary announced a full asset freeze on VTB, Russia's second-largest bank (£154bn in assets, 95,000 employees), alongside a freeze on all Russian bank assets in the UK and a ban on Russian companies raising finance on UK markets. The package designated more than 100 companies and individuals -- including five major defence firms (Rostec, Uralvagonzavod, Tactical Missile Corporation, United Aircraft Corporation, United Shipbuilding Corporation) and Putin-inner-circle figures such as Kirill Shamalov -- for asset freezes and travel bans. Aeroflot was banned from UK airspace and new export controls were imposed on electronics, telecommunications and aerospace goods to Russia.

OFAC codified the Chinese Military-Industrial Complex Sanctions Regulations at 31 CFR Part 586, implementing Executive Order 13959 (November 12, 2020) as amended by Executive Order 14032 (June 3, 2021). The regulations prohibit US persons from purchasing or selling publicly traded securities of entities designated on OFAC's Non-SDN Chinese Military-Industrial Complex Companies (NS-CMIC) List, which identifies firms determined to support the People's Liberation Army or Chinese surveillance-technology programs. A divestment deadline of June 3, 2022 applied to entities named in the original EO 13959 annexes; future additions carry a one-year divestment window from the date of designation.