Sanctions in Respect of Ukraine and Russia

EU Sanctions

The EU published Regulation 833/2014 on 31 July 2014, detailing further measures against Russia in light of the situation in Ukraine. In brief, the Regulation prohibits the supply, transfer or export of:

• Dual-use goods, whether originating in the EU or not, to Russian persons or for use in Russia if they are intended for military use.
• Goods set out in Annex II of the Regulation - which relate to oil exploration and production activities in Russia - without prior authorisation from a competent authority.
• Technical assistance, brokerage or financial services related to goods and technology in the Common Military List.

The text of the Regulation can be found here Offical Journal of the EU Regulations. As usual it has wide application to persons and vessels within the EU or subject to the jurisdiction of an EU Member State (see Article 13).

In addition, the EU has further expanded the number of individuals and entities to which travel plans and asset freezes have been applied. The Notice issued by the UK Treasury dated 31 July 2014 can be found here Financial Sanctions Notice: Ukraine.

Members are strongly advised to proceed with caution when dealing with Russian or Ukrainian counterparties and to satisfy themselves that no sanctioned individual or entity is involved in the potential trade.  Failure to do so may result in exposure to EU and/or US sanctions and to the loss of Club cover.

Russian Sanctions

Russia has recently issued its own embargo on the importation into the Russian Federation of beef, pork, fruit and vegetable produce, poultry, fish, cheese, milk and dairy products where they originate from the US, an EU state, Canada, Australia or Norway.

Members should contact the Managers with any questions concerning the impact of these and any other sanctions - Tony.Paulson@westpandi.com or Robert.Searle@westpandi.com.