Sanctions’ nature

Spheres (individuals) affected

1st wave

March 2014

Suspension   of collaboration with the Russian Federation in certain spheres

• Defense complex;
• Investment construction;
• Space exploration.

Approval of   lists with individuals on which the “personal” sanctions are imposed,   including:

• Ban on entering the USA and EU countries;
• Freeze on foreign assets;
• Ban for residents of the USA and EU countries on entering into any   contractual relations with the persons affected by sanctions

Certain Russian   and Crimean officials “responsible for destabilization of the situation in Ukraine,” in particular: S.M. Mironov, A.A. Klishas,   S.V. Aksenov, V.A. Konstantinov, V.Yu. Surkov.

2nd wave

March 2014

–

July 2014

Periodic expansion   of the lists of individuals subject to “personal” sanctions

• Russian and Crimean officials;
• Military;
• Businessmen, “people close to V.V. Putin”   (Arkady and Boris Rotenberg, Gennady Timchenko and Vladimir Yakunin) and   organizations “maintaining interests of chief executive officers of Russia” (Rossiya   Bank and its group of entities, Sobinbank, Volga Group, Transoil, etc.)

3rd wave

July 2014

–

August 2014

Introducing   “sectoral” sanctions.

 USA:

• Restriction on equipment supply for mining operations in Russia;
• Restriction on financing certain banks of the Russian Federation with state   participation and their property for a period over 90 days

 EU:

• Sanctions related to Crimea (ban on investments in certain industries;   on purchasing over 250 types of goods; issue of loans, purchasing shares in   projects related to “sectoral” sanctions);
• Embargo on import and export of weapons; ban on export to Russia (for   Russian customers) of dual use goods, and technologies for military use;
• Ban on transactions with primary securities and instruments of   currency market in relation to Russian banks with state participation;
• Establishment of authorization procedure for export of certain   equipment and technologies of energy service purpose into the Russian   Federation;
• Including Dobrolet airline (subsidiary of Aeroflot) in the sanctions lists   with regard to servicing Moscow-Simferopol flights

• Financial sector;
• Oil and gas sector;
• Energy service sector;
• Defense industry;
• Civil aviation.

Responsive sanctions of Russia

March 2014

–

August 2014

  “Personal”   and “sectoral” sanctions:

 - Certain officials of EU, USA and Canada are prohibited from entering   the Russian Federation (additionally, the list of individuals in relation to   which the sanctions are imposed was approved; it is not subject to public   disclosure);

 - Russia announced a ban on transit flights of Ukrainian airlines through   the Russian air space as a responsive sanction to EU’s sanctions against   Dobrolet airline.

 - Ban on import of agricultural products:

• On August 06, 2014 import of agricultural products (meat and dairy   products, fish, vegetables, fruits and nuts), whose country of origin   introduced economic sanctions in relation to Russian legal entities and/or   individuals, is prohibited in the Russian Federation;
• On August 20, 2014 for the benefit of diabetics and persons with   allergies and the entrepreneurs dependent on import of production materials   the following products are excluded from the list of banned goods: delactosed   milk and milk products; nutritional supplements; vitamin-mineral complexes;   flavors; protein concentrates (animal and vegetable) and their mixes; dietary   fibers and food supplements (including complex); alevins of Atlantic salmon   and trout; certain species of inocula.

• Agriculture;
• International trade;
• Civil aviation.

4th wave

September 2014

 Expansion   of the lists of individuals subject to “personal” sanctions and   intensification of sanctions in financial and energy sectors and defense   industry.

 EU:

 - List of individuals the “personal” sanctions can be imposed on is expanded   and includes:

• Individuals responsible for destabilization of the situation in   Ukraine (including those who actively support or endanger its territorial   integrity, etc.);
• Individuals providing material or financial support or benefiting from   damaging the territorial integrity of Ukraine and Russian individuals   responsible for annexation of Crimea;
• Individuals making transactions with militiamen of the Donbass Region;

 - Sanctions in the financial sphere:

• Ban on rendering investment services to banks and fuel and energy   companies with state participation, defense enterprises, as well as a ban on   operations with their new obligations and other securities issued starting   from September 12, 2014, with the maturity period over 30 days;
• Ban on issuing loans to the said organizations for a period over 30   days;

 - Ban on rendering services on oil development and production in deep   waters, the Arctic and shale deposits of Russia;

 - Ban on supply of dual use goods to certain enterprises of the Russian   defense complex.

• Financial sector;
• Oil and gas sector;
• Energy service sector;
• Defense industry.

• Personal   sanctions in relation to Russian politicians who supported the annexation of   Crimea, including V.V. Zhirinovsky, L.I. Kalashnikov,   S.S. Zhurova and others, militiamen of the Donbass People’s Republic.

• Banks   with state participation: Sberbank, VTB, Gazprombank, VEB and Russian   Agricultural Bank (Rosselkhosbank).

• Russian   defense enterprises: Oboronprom, United Aircraft Corporation and   UralVagonZavod corporation are imposed    financial sanctions; AO Kalashnikov and JSC Tulsky Oruzheiny Zavod,   etc. are banned for supply of dual use goods.

• Fuel and   energy companies: Rosneft, Transneft and Gazprom Neft.

Responsive sanctions of Russia

September 2014

Russian   authorities announced that the responsive measures related to sanctions   introduced by EU in September 2014 are under development and, in particular, could restrict importing automobiles and clothing manufactured by western countries. The responsive measures have not been officially adopted yet, but   it is highly probable that they will be published.

  Igor Gorokhov
  Senior Associate

  Saint-Petersburg
  Тел.: +7 (812) 346 79 90