EU & US Sanctions Alert: new and expected measures for the 2nd anniversary of the war in Ukraine and Alexei Navalny’s death

Last Friday, the European Union (EU) and the United States (US) imposed further sanctions against Russia, marking the second anniversary of its invasion of Ukraine and in retaliation to the death of Kremlin critic Alexei Navalny.

These measures were followed by a G7 statement issued on Saturday 24 February, in which the G7 nations committed to continue imposing sanctions on Russia and targeting those involved in sanctions evasion.

Below is a breakdown of the latest sanctions updates by jurisdiction and the specific measures imposed:

I. EU Sanctions Update

Adopted Measures

Last week, the Council of the EU adopted its 13th sanctions package against Russia and Member States reportedly reached a political agreement on the renewal of individual designations:

Overview of the EU’s 13th Sanctions Package against Russia:

• The package was formally adopted on 23 February, focusing on individual designations without introducing new trade restrictions or sectoral measures.
• 105 individuals and 88 entities have been sanctioned, targeting Russian military sector executives, defence and government officials, regional governors, and companies engaged in military operations.
• 27 military and tech firms from Russia, China, Kazakhstan, Serbia, India, Sri Lanka, Thailand, and Turkey, have been added to the list of those supporting Russia’s military and industrial complex, and are now facing import restrictions on dual-use goods and technologies.
• The United Kingdom has been added to the list of partner countries applying restrictive measures on imports of iron and steel from Russia.

Renewal of Individual Designations:

• A political agreement has been reached on the extension of targeted sanctions for another six months from 15 March 2024.
• The delisting of a small number of individuals is currently under consideration, including Yandex founder Arkady Volozh, former Sistema executive Sergey Mndoiants, and Slovak businessman Jozef Hambalek.
• Despite Hungary’s reported efforts to advocate for the removal of Alisher Usmanov, Moshe Kantor, and Nikita Mazepin, they are expected to remain on the EU’s sanctions list.

Expected Measures

It has also been reported last week that the EU will impose new sanctions against Russia, and that the initial work on the EU’s 14th sanctions package has already started:

EU to impose sanctions after the death of Alexei Navalny

Russian opposition leader Alexei Navalny died on 19 February, and in a press release the Council of the EU stated “the EU will spare no efforts to hold Russia’s political leadership and authorities to account, in close coordination with our partners; and impose further costs for their actions, including through sanctions”.

EU’s High Representative Josep Borrell indicated that the new sanctions will include asset freezes and travel bans against people or entities suspected of involvement in Navalny’s death, without specifying the exact timeline for these possible sanctions. He also suggested renaming the EU’s human rights sanctions regime in Navalny’s honour.

EU’s 14th Sanctions Package against Russia

The EU is reportedly already working on its 14th sanctions package against Russia, which might include new trade restrictions as well, in addition to individual designations.

II. US Sanctions Update

The US also adopted a significant set of sanctions against Russia on the anniversary of the war, and in part as a response to the death of Alexei Navalny. The sanctions, imposed by the Treasury, the State Department, and the Commerce Department, target over 600 people and entities, including officials involved in the death of Alexei Navalny.

Overview of the latest US sanctions against Russia:

• Individual sanctions targeted over 500 people and entities in response to the war’s anniversary and Alexei Navalny’s death.
• Measures focus on state-owned Russian entities, entities in third countries involved in sanction circumvention, and the military and industrial sectors including gold, pipe, and aluminium producers.
• The US introduced sanctions against the National Payment Card System “Mir”, leading tanker group Sovcomflot, and various Russian financial institutions including SPB Bank.
• New trade restrictions have been imposed on entities from Russia, China, Turkey, the UAE, Kyrgyzstan, India, and South Korea, for supporting Russia’s war effort in Ukraine.
• Energy capabilities have also been targeted by sanctioning companies involved in Liquefied Natural Gas (LNG) projects.
• Companies involved in weapons manufacturing, the nuclear sector, and military cooperation with North Korea and Iran have also been sanctioned.