By Maya Lester QC & Michael O’Kane

Sanctions Profile: Russia

At a glance

EU sanctions on Russia were introduced in 2014 in response to Russia’s involvement in the Ukraine crisis, during which Russia annexed the Crimea region of Ukraine. They were introduced in three phases, each one intending to increase the pressure on Russia until it fully implemented the terms of the Minsk peace agreements.

In 2022, further sectoral and targeted sanctions against Russia were adopted in response to Russia’s aggression against Ukraine, including the recognition of the so-called People’s Republics of Donetsk (DNR) and Luhansk (LNR) and the following invasion of Ukraine.

The UK adopted The Russia (Sanctions) (EU Exit) Regulations 2019 in January 2021 (at the end of the Brexit transition period) to encourage Russia to cease actions which destabilise Ukraine, including actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine. In February and March 2022, the UK adopted numerous amendments to the Regulations in response to Russia’s aggression against Ukraine. The legislative instruments are listed on this page.

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Sanctions debates in the House of Commons

On Thursday (22 September 2022), 2 sanctions-related debates were held in the House of Commons: ‘Sanctions’ and ‘Ukraine’. The key points are summarised below. Sanctions Stephen Doughty MP: requested further information about the resourcing of the FCDO sanctions taskforce and OFSI, noting that he was informed by the current Foreign Secretary in May that 150 people were working full time …


UK fine wine fine

OFSI today published details of a £30,000 monetary penalty imposed on Hong Kong International Wine and Spirits Competition Ltd (HKIWSC) for violating regulations 3(1) and 6(1) of the Ukraine (European Union Financial Sanctions) (No.2) Regulations 2014 and articles 2(1) and 2(2) of the Council Regulation (EU) No 269/2014. Notice. Between September 2017 and August 2020, HKIWSC are said to have …


UK adds 89 people & 3 entities to Russia sanctions list

The UK today added 89 people and 3 entities to its Russia sanctions list in response to the “sham referendums” that have taken place in 4 non-government-controlled regions of Ukraine. Press Release & Notice. Those listed include: Russian “officials and collaborators” involved in the organisation of the referendums, including: Sergei Yeliseyev (Head of the Government in Kherson), Ivan Kusov (Luhansk …


EU to adopt further Russia sanctions & discusses switch to QMV

In response to the latest escalation in the Russia’s aggression against Ukraine and the organisation of “illegal referenda” in non-government-controlled areas of Ukraine, the EU has declared that further EU sanctions will be brought forward as soon as possible in coordination with its partners. High Representative Josep Borrell has said that although the EU has “already done almost everything possible”, …


OFAC imposes restrictions on Russia quantum computing sector & issues 2 GLs

Alongside the additional Russia designations and export controls imposed by the US last week (previous post), OFAC issued a Determination Pursuant to Section 1(a)(i) of Executive Order (E.O.) 14024 and a Determination Pursuant to Section 1(a)(ii) of E.O. 14071, as well as 2 Russia-related General Licences (GLs). These are summarised below. OFAC Press Release, Notice, Notice & Notice. Determination Pursuant …


Current Sanctions


Consolidated - Sectoral Sanctions

Council Regulation (EU) 833/2014

Parent Regulation - Sectoral Sanctions

Council Regulation (EU) 833/2014

Amended by:

Council Regulation (EU) 960/2014

Council Regulation (EU) 1290/2014

Council Regulation (EU) 2015/1797

Council Regulation (EU) 2017/2212

Council Regulation (EU) 2022/262

Council Regulation (EU) 2022/328

Council Regulation (EU) 2022/334

Council Regulation (EU) 2022/345

Council Regulation (EU) 2022/350

Council Regulation (EU) 2022/428

Council Regulation (EU) 2022/576

Council Regulation (EU) 2022/879

Council Implementing Regulation (EU) 2022/994

Council Regulation (EU) 2022/1269

Consolidated - Sectoral Sanctions

Council Decision 2014/512/CFSP

Parent Decision - Sectoral Sanctions

Council Decision 2014/512/CFSP

Amended by:

Council Decision 2014/659/CFSP

Council Decision 2014/872/CFSP

Council Decision (CFSP) 2015/971

Council Decision (CFSP) 2015/1764

Council Decision (CFSP) 2015/2431

Council Decision (CFSP) 2016/1071

Council Decision (CFSP) 2016/2315

Council Decision (CFSP) 2017/1148

Council Decision (CFSP) 2017/2214

Council Decision (CFSP) 2017/2426

Council Decision (CFSP) 2018/964

Council Decision (CFSP) 2018/2078

Council Decision (CFSP) 2019/1108

Council Decision (CFSP) 2020/907

Council Decision (CFSP) 2020/2143

Council Decision (CFSP) 2021/448

Council Decision (CFSP) 2021/1144

Council Decision (CFSP) 2022/52

Council Decision (CFSP) 2022/264

Council Decision (CFSP) 2022/327

Council Decision (CFSP) 2022/335

Council Decision (CFSP) 2022/346

Council Decision (CFSP) 2022/351

Council Decision (CFSP) 2022/430

Council Decision (CFSP) 2022/578

Council Decision (CFSP) 2022/884

Council Decision (CFSP) 2022/995

Council Decision (CFSP) 2022/1271

Council Decision (CFSP) 2022/1313

Consolidated - Ukraine Territorial Integrity

Council Regulation (EU) 269/2014

Parent Regulation - Ukraine Territorial Integrity

Council Regulation (EU) 269/2014

Amended by:

Council Implementing Regulation (EU) 284/2014

Council Implementing Regulation (EU) 433/2014

Council Regulation (EU) 476/2014

Council Implementing Regulation (EU) 477/2014

Council Implementing Regulation (EU) 577/2014

Council Implementing Regulation (EU) 753/2014

Council Regulation (EU) 783/2014

Council Implementing Regulation (EU) 810/2014

Council Regulation (EU) 811/2014

Council Implementing Regulation (EU) 826/2014

Council Regulation (EU) 959/2014

Council Implementing Regulation (EU) 961/2014

Council Implementing Regulation (EU) 1225/2014

Council Implementing Regulation (EU) 1270/2014

Council Implementing Regulation (EU) 2015/240

Council Implementing Regulation (EU) 2015/427

Council Implementing Regulation (EU) 2015/1514

Council Implementing Regulation (EU) 2016/353

Council Implementing Regulation (EU) 2016/1661

Council Implementing Regulation (EU) 2016/1955

Council Implementing Regulation (EU) 2017/437

Council Implementing Regulation (EU) 2017/1374

Council Implementing Regulation (EU) 2017/1417

Council Regulation (EU) 2017/1547

Council Implementing Regulation (EU) 2017/1549

Council Implementing Regulation (EU) 2017/2153

Council Implementing Regulation (EU) 2018/388

Council Implementing Regulation (EU) 2018/705

Council Implementing Regulation (EU) 2018/1072

Council Implementing Regulation (EU) 2018/1230

Council Implementing Regulation (EU) 2018/1929

Council Implementing Regulation (EU) 2019/92

Council Implementing Regulation (EU) 2019/352

Council Implementing Regulation (EU) 2019/1403

Council Implementing Regulation (EU) 2020/119

Council Implementing Regulation (EU) 2020/1267

Council Implementing Regulation (EU) 2020/1367

Council Implementing Regulation (EU) 2021/446

Council Implementing Regulation (EU) 2021/1791

Council Implementing Regulation (EU) 2021/2193

Council Implementing Regulation (EU) 2022/236

Council Implementing Regulation (EU) 2022/260

Council Regulation (EU) 2022/259

Council Implementing Regulation (EU) 2022/261

Council Regulation (EU) 2022/330

Council Implementing Regulation (EU) 2022/332

Council Implementing Regulation (EU) 2022/336

Council Implementing Regulation (EU) 2022/353

Council Implementing Regulation (EU) 2022/396

Council Implementing Regulation (EU) 2022/408

Council Implementing Regulation (EU) 2022/427

Council Regulation (EU) 2022/580

Council Implementing Regulation (EU) 2022/581

Council Regulation (EU) 2022/625

Council Implementing Regulation (EU) 2022/658

Council Implementing Regulation (EU) 2022/878

Council Regulation (EU) 2022/880

Council Implementing Regulation (EU) 2022/1270

Council Regulation (EU) 2022/1273

Council Implementing Regulation (EU) 2022/1274

Council Implementing Regulation (EU) 2022/1354

Council Implementing Regulation (EU) 2022/1446

Consolidated - Ukraine Territorial Integrity

Council Decision 2014/145/CFSP

Parent Decison - Ukraine Territorial Integrity

Council Decision 2014/145/CFSP

Amended by:

Council Implementing Decision 2014/151/CFSP

Council Implementing Decision 2014/238/CFSP

Council Decision 2014/265/CFSP

Council Decision 2014/308/CFSP

Council Decision 2014/455/CFSP

Council Decision 2014/475/CFSP

Council Decision 2014/499/CFSP

Council Decision 2014/508/CFSP

Council Decision 2014/658/CFSP

Council Decision 2014/801/CFSP

Council Decision 2014/855/CFSP

Council Decision (CFSP) 2015/241

Council Decision (CFSP) 2015/432

Council Decision (CFSP) 2015/1524

Council Decision (CFSP) 2016/359

Council Decision (CFSP) 2016/1671

Council Decision (CFSP) 2016/1961

Council Decision (CFSP) 2017/445

Council Decision (CFSP) 2017/1386

Council Decision (CFSP) 2017/1418

Council Decision (CFSP) 2017/1561

Council Decision (CFSP) 2017/2163

Council Decision (CFSP) 2018/392

Council Decision (CFSP) 2018/706

Council Decision (CFSP) 2018/1085

Council Decision (CFSP) 2018/1237

Council Decision (CFSP) 2018/1930

Council Decision (CFSP) 2019/95

Council Decision (CFSP) 2019/354

Council Decision (CFSP) 2019/1405

Council Decision (CFSP) 2020/120

Council Decision (CFSP) 2020/1269

Council Decision (CFSP) 2020/1368

Council Decision (CFSP) 2021/1470

Council Decision (CFSP) 2021/1792

Council Decision (CFSP) 2021/2196

Council Decision (CFSP) 2022/241

Council Decision (CFSP) 2022/265

Council Decision (CFSP) 2022/267

Council Decision (CFSP) 2022/329

Council Decision (CFSP) 2022/331

Council Decision (CFSP) 2022/337

Council Decision (CFSP) 2022/354

Council Decision (CFSP) 2022/397

Council Decision (CFSP) 2022/411

Council Decision (CFSP) 2022/429

Council Decision (CFSP) 2022/582

Council Decision (CFSP) 2022/627

Council Decision (CFSP) 2022/660

Council Decision (CFSP) 2022/883

Council Decision (CFSP) 2022/885

Council Decision (CFSP) 2022/1272

Council Decision (CFSP) 2022/1276

Council Decision (CFSP) 2022/1355

Council Decision (CFSP) 2022/1447

Consolidated - Crimea & Sevastopol

Council Regulation (EU) 692/2014

Parent Regulation - Crimea & Sevastopol

Council Regulation (EU) 692/2014

Amended by:

Council Regulation (EU) 825/2014

Council Regulation (EU) 1351/2014

Consolidated - Crimea & Sevastopol

Council Decision 2014/386/CFSP

Parent Decision - Crimea & Sevastopol

Council Decision 2014/386/CFSP

Amended by:

Council Decision 2014/507/CFSP

Council Decision 2014/933/CFSP

Council Decision (CFSP) 2015/959

Council Decision (CFSP) 2016/982

Council Decision (CFSP) 2017/1087

Council Decision (CFSP) 2018/880

Council Decision (CFSP) 2019/1018

Council Decision (CFSP) 2020/850

Council Decision (CFSP) 2021/1010

Council Decision (CFSP) 2022/962

Consolidated - Donetsk & Luhansk

Council Regulation (EU) 2022/263

Parent Regulation - Donetsk & Luhansk

Council Regulation (EU) 2022/263

Amended by:

Council Regulation (EU) 2022/626

Consolidated - Donetsk & Luhansk

Council Decision (CFSP) 2022/266

Parent Decision - Donetsk & Luhansk

Council Decision (CFSP) 2022/266

Amended by:

Council Decision (CFSP) 2022/628

Visa restrictions

Council Decision (EU) 2022/333

Consolidated Regulation

Russia (Sanctions) (EU Exit) Regulations 2019, SI 2019/855

Parent Regulation

Russia (Sanctions) (EU Exit) Regulations 2019, SI 2019/855

Export Control (Amendment) (No. 2) Order 2019 (SI 2019/1159)

The Russia (Sanctions) (Overseas Territories) Order 2020

The Russia (Sanctions) (Overseas Territories) (Amendment) Order 2021

The Russia (Sanctions) (EU Exit) (Amendment) Regulations 2022

The Russia (Sanctions) (EU Exit) (Amendment) (No. 2) Regulations 2022

The Russia (Sanctions) (EU Exit) (Amendment) (No. 3) Regulations 2022

The Russia (Sanctions) (EU Exit) (Amendment) (No. 4) Regulations 2022

The Russia (Sanctions) (EU Exit) (Amendment) (No. 5) Regulations 2022

The Russia (Sanctions) (EU Exit) (Amendment) (No. 6) Regulations 2022

The Russia (Sanctions) (EU Exit) (Amendment) (No. 7) Regulations 2022

The Russia (Sanctions) (EU Exit) (Amendment) (No. 8) Regulations 2022

The Russia (Sanctions) (EU Exit) (Amendment) (No. 9) Regulations 2022

The Russia (Sanctions) (EU Exit) (Amendment) (No. 10) Regulations 2022

The Russia (Sanctions) (EU Exit) (Amendment) (No. 11) Regulations 2022 SI 2022/792

The Russia (Sanctions) (EU Exit) (Amendment) (No. 12) Regulations 2022 SI 2022/801

The Russia (Sanctions) (EU Exit) (Amendment) (No. 13) Regulations 2022 SI 2022/814

The Russia (Sanctions) (EU Exit) (Amendment) (No. 14) Regulations 2022 SI 2022/850

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