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Sanctions as a result of the situation in Ukraine and Russia

Thursday, 28 August, 2014

Due to the political situation in Ukraine, the European Union (EU) has taken a number of decisions to impose targeted sanction against individuals and companies in Russia and Ukraine, and goods exported from the EU to Russia. The United States (US) have also imposed similar sanctions.
 
Diamonds

The current sanctions are not targeting the trade in diamonds. Importing diamonds from Russia or exporting diamonds to Russia, as well as the financing of this trade is still permitted. The Antwerp World Diamond Centre (AWDC) does not expect any future sanctions that will affect trade in diamonds.
 
Individuals and companies in Russia

A number of companies and individuals from Russia, the Crimea and the occupied territories in Ukraine have been put on a sanctions list. This means that their funds are frozen and that they have no more access to the EU. These companies and individuals have a direct impact on the annexation of the Crimea. You will find the full list on the following websites:
 
-        http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02014D0145-20140321&qid=1409208584541
-        http://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1409208848402&uri=CELEX:32014D0499
-        http://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1409208975237&uri=CELEX:32014D0508
 
 
Restrictions on trade with Russia

In late July, the EU imposed additional sanctions. For the first time, restrictions were placed on the export of goods from the EU to Russia. The arms trade between the EU and Russia was prohibited. Exports of dual-use goods to Russia is also not allowed.
 
In addition, a license must be requested for exports of certain goods, which could be used for the exploration or production of oil from deep water reserves, from the polar region or for the production of shale oil. Diamonds are not on the exhaustive list of goods. However, the export of products with the HS code 8207 19 10 requires an export license. These are the end products, which are used to process diamonds, namely rock-drilling or earth-boring tools, interchangeable, with working parts of diamond or agglomerated diamond. The full list of goods for which an export license must be requested can be found on the following website:
 
http://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1409209532270&uri=CELEX:32014R0833
 
A final EU restrictive measure targets a number of Russian banks, namely banks with over 50% public ownership or banks controlled by the state for more than 50%, as well as all legal entities, which are at least 50% owned by one of these banks and legal persons, entities or bodies acting on behalf of these banks.
 
The measure prohibits the direct or indirect sale or purchase of, the provision of brokering services or assistance in the issuance of, or any other act relating to bonds, equities or similar financial instruments with a maturity exceeding 90 days that are issued after 1 August 2014.
 
This means that the EU-financing of these banks is being depleted. The measure is limited to the (inter-bank) financing, and has no impact on the regular commercial activities of or with these banks. Performing transfers to these banks, for example, for the payment or financing of diamond, is not prohibited. The banks are the following:
 
1.    SBERBANK
2.    VTB BANK
3.    GAZPROMBANK
4.    VENSHECONOMBANK (VEB)
5.    ROSSELKHOZBANK
 
More information concerning these restrictive measures is available herr:
 
http://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1409209015739&uri=CELEX:32014D0512
 
 
Sanctions imposed by the United States

The United States has imposed sanctions similar to those of EU, also putting individuals and businesses on a sanctions list. You can find the names here https://sdnsearch.ofac.treas.gov . The US has also imposed restrictions on the financing of a number of Russian banks. These measures have no impact on the daily commercial transactions with Russian banks, but target the financing of these institutions in the medium and long term. The measures apply to the following banks:
 
1.    BANK OF MOSCOW
2.    VTB BANK
3.    GAZPROMBANK
4.    VNESHECONOMBANK (VEB)
5.    ROSSELKHOZBANK
 
Vigilance measures of European banks

As a result of these sanctions European banks are taking additional due diligence measures when conducting transactions with Russia, especially with the banks on the EU and US sanctions lists. With these additional checks European banks want to ensure that they themselves do not breach sanctions, for example by allowing payments that the are ultimately destined for individuals or companies that have been sanctioned.
 
 
Unsure about what you are allowed and are not allowed to do?

AWDC’s Public Affairs department is closely following the developments in this dossier. For questions concerning this topic you are always welcome to send an email to publicaffairs@awdc.eu, or to contact us by phone at 03 222 07 11.​