Russia/Ukraine Sanctions Update - Month of February

US Sanctions | EU Sanctions | UK Sanctions | Russia/Ukraine Sanctions | Other Notable Developments 

I.  US SANCTIONS

• U.S. Department of the Treasury Sanctions Key Infrastructure that Enables Russia-Based Ransomware Attacks: On February 11, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), jointly with Australia and the United Kingdom, designated Zservers, a Russia-based bulletproof hosting (“BPH”) services provider, and two Russian nationals who were determined to operate Zservers, for their alleged role in supporting LockBit ransomware attacks. As a BPH service provider, Zservers provided cybercriminals, including LockBit, a Russia-based ransomware group, access to specialized servers and other computer infrastructure designed to resist law enforcement action. Read more>>
  
• U.S. Justice Department Announces Sentencing of Israeli Freight Forwarder for Russia Sanctions Violations: On February 21, the Justice Department announced it sentenced an Israeli freight forwarder to 24 months in prison and three years of supervised release for conspiracy to illegally ship aircraft parts and avionics from U.S. manufacturers and suppliers to Russia, including for the benefit of sanctioned Russian airline companies. Read more>>
• U.S. Justice Department Charges Ohio-Based Supplier of Aircraft Parts with Russian Export Scheme: On February 13, the Justice Department announced it charged Flighttime Enterprises, Inc., an American subsidiary of a Russian aircraft parts supplier, along with three of its current and former employees, with crimes related to an alleged scheme to illegally export aircraft parts and components from the U.S. to Russia and Russian airline companies without the required licenses from the Department of Commerce. Read more>>
• U.S. Secretary of State Meeting with Russian Foreign Minister: On February 18, U.S. Secretary of State, Marco Rubio, met with Russian Foreign Minister, Sergei Lavrov. The parties agreed to several measures, including to “[a]ppoint respective high-level teams to begin working on a path to ending the conflict in Ukraine as soon as possible in a way that is enduring, sustainable, and acceptable to all sides.” Read more>>
• U.S. Secretary of State Call with Russian Foreign Minister: On February 15, U.S. Secretary of State, Marco Rubio, spoke with Russian Foreign Minister, Sergei Lavrov, as a follow up to President Trump’s conversation with Russian President, Vladimir Putin, and to reaffirm President Trump’s commitment to finding an end to the conflict in Ukraine. They also “discussed the opportunity to potentially work together on a number of other bilateral issues.” Read more>>
• U.S. Secretary of State Call with Ukrainian Foreign Minister: On February 13, U.S. Secretary of State, Marco Rubio, spoke with Ukrainian Foreign Minister, Andrii Sybiha, to discuss “the need for bold diplomacy to end the war in a negotiated manner leading to a sustainable peace.” Secretary Rubio also “underscored U.S. commitment to Ukrainian independence and the stability of Ukraine and the region.” Read more>>

II.  EU Sanctions

• EU Adopts 16th Sanctions Package Against Russia: On February 24, the EU adopted the 16th package of sanctions against Russia, correspondingly aligned sanctions targeting Belarus and reinforced sanctions relating to Crimea/Sevastopol and the non-government-controlled areas of Ukraine in the Donetsk, Kherson, Luhansk and Zaporizhzhia oblasts. Full summary of the 16th package is available here. Read more>>, Read more>>, Read more>>, Read more>>, Read more>> and Read more>>
  
• EU Sanctions Against Belarus Extended for a Further Year: On February 24, the EU prolonged and updated the list of individuals and entities subject to restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine until February 28, 2026. Read more>> and Read more>>
  
• European Commission Updates FAQs on EU Sanctions: The updated FAQs on sanctions against Russia issued in February 2025 cover the sanction topics on provision of services, and matters related to Donetsk, Kherson, Luhansk and Zaporizhzhia oblasts. Read more>> and Read more>>
• EU's General Court Dismisses Action Against EU Sanctions Brought by Aleksandra Melnichenko: By its judgment delivered on February 26, the General Court dismissed the action brought by Ms. Aleksandra Melnichenko challenging her listings. Read more>>
• EU's General Court Annuls the Sanction Listing of Maya Tokareva: In its judgment delivered on February 26, the General Court annulled the extension of Ms. Maya Tokareva's designation from March to September 2024. This decision follows a judgment on September 11, 2024, which had previously removed earlier designations of September 2022, March 2023, and September 2023. Read more>>
• Swedish Court Seeks Clarification from the Court of Justice of the EU on the "No-Claims" Provision in the EU's Russia Sanctions: The Svea hovrätt (Court of Appeal, Stockholm, Sweden) has requested a preliminary ruling from the Court of Justice of the EU on three issues pertaining to Article 11(1) of Council Regulation (EU) No 833/2014. This article includes a "no claim" clause, which provides that Russian parties cannot seek compensation for compliance with the obligations imposed by the EU sanctions against Russia. The first issue is whether the Regulation precludes parties from settling claims that cannot be granted under Article 11(1) and whether such settlement agreements are void. The second issue is whether any national court hearing an application for setting aside or annulment of an arbitral award must, of its own motion, scrutinize the compatibility of the tribunal’s decision with the Regulation and in case it finds that the tribunal’s legal approach was contrary to it, set aside or annul the award. The third issue is whether claims for refunds of advance payments for undelivered goods and interest on such claims are precluded by the Regulation. Read more>> and Read more>>
• Impact of Sanctions on EU Companies: The European Commission explained that the sanctions against Russia and Belarus are designed to impose significant costs on these countries while minimizing negative effects on the EU, its citizens, and businesses. The Commission added that the EU has supported Ukraine by providing duty and quota-free access for its agricultural products to the EU market, and its monitoring has shown no adverse impact on the EU market from these measures. Read more>> and Read more>> 
• Sanctioning and Deterring Hybrid Operations: EU's High Representative and Vice-President Ms. Kaja Kallas explained that in response to Russia's intensified hybrid campaign, the EU has implemented several measures, including the adoption of a hybrid sanctions regime and the operationalization of Hybrid Rapid Response Teams to bolster resilience against hybrid threats. On October 8, 2024, the High Representative condemned Russia's actions, and the Council adopted sanctions targeting individuals and entities involved in destabilizing activities. Additionally, the EU is enhancing efforts to protect critical infrastructure, such as undersea cables, and is working closely with international partners to improve situational and maritime domain awareness. Read more>> and Read more>>
• Belaruskali Demands €12bn in Damages from Lithuania over Transit Sanction: Belaruskali, a Belarusian potash fertilizer producer, is seeking €12 billion in damages from Lithuania through an international arbitration lawsuit, claiming that Lithuania's suspension of transit shipments in 2022 violated a bilateral investment agreement. Lithuania, supported by EU sanctions, maintains that its actions were lawful and justified, with the arbitration case set to be heard in Geneva. Read more>>
• Lithuanian Customs Seize Vehicles and Arrest Four in Major Sanctions Violation Investigation: Lithuania's Customs Criminal Service conducted searches in Vilnius and Rudamina, detaining 17 trucks and 15 semi-trailers worth 1.5 million euros, and arrested four individuals as part of an investigation into violations of international sanctions involving the illegal transport of vehicles to Russia and Belarus. The investigation revealed that 30 vehicles, including luxury cars, were suspected to have been illegally exported, and smuggled cigarettes were also found during the searches. Read more>>
• Russian Role in Buying Software for EU Border System Probed: The European Public Prosecutor’s Office is investigating the involvement of the French IT group Atos's Moscow office in procuring software for the EU's new electronic border system, raising significant security concerns due to the potential access granted to Russia's FSB. According to documents seen by the Financial Times, Atos used staff in Russia to buy software in 2021 for the highly sensitive project, which aims to gather and store biometric data on all non-EU visitors to the EU. Despite internal measures and investigations by EU agencies, no security breaches have been identified, but the project's launch remains uncertain due to technical issues and the sensitive nature of the data involved. Read more>> (subscription required)
• Boeing and Airbus Shipments Passed on to Russia via India, Despite Sanctions: Indian intermediaries have been re-exporting aircraft parts from Western firms to Russia, despite strict sanctions from the EU, UK, and US, according to customs data analyzed by Investigate Europe. These parts, including critical components like generators and cockpit displays, have been traced from Western companies to India and then to Russian airlines. While there is no evidence of illegality by the Western suppliers, the investigation highlights India's role as a key transit route for Russia's aviation industry, with some Indian companies flagged for sanctions evasion. Read more>>
• Azerbaijani NGOs Urge US and EU to Act Against Armenia's Role in Russian Sanctions Evasion: A coalition of Azerbaijani NGOs has expressed deep concern over Armenia's role in enabling Russia to bypass international sanctions imposed due to the war in Ukraine. They highlight a significant increase in Armenia's trade with Russia, particularly in high-tech goods, suggesting potential violations of sanctions that support Russia's military efforts. The NGOs urge the US and EU to tighten oversight of Armenia's trade, enhance sanctions enforcement, and increase diplomatic pressure on Armenia to cease its support for Russia. Read more>>

III.  UK Sanctions

• UK Government removes one entry from the UK sanctions list under the Russia regime: On February 26, OFSI removed Francois Edouard Mauron from the UK sanctions list under the Russia regime.  Mauron was designated in November 2023 for obtaining a benefit from or supporting the Government of Russia by working as a director in a business of strategic significance to Russia's energy sector. Read more>>
• UK Government updates guidance on countering Russian sanctions evasion: On February 25, OFSI updated its guidance on countering Russian sanctions evasion, which seeks to support UK exporters in understanding Russian circumvention practices and mitigate the risk of businesses being targeted by those seeking to evade sanctions.  The updated guidance provides additional information on the level of risk the government is willing to accept when assessing export licence applications for Common High Priority List items subject to export controls, where there is a lack of certainty regarding the end-use or end user (such as items destined for stock), and where the UK Government assesses there is a risk of diversion to Russia. Read more>> and Read more>>
• UK Government imposes more than 100 new sanctions under the Russia regime: On February 24, the UK Government added 67 new entries to the UK sanctions list and specified 40 new ships under the Russia regime.  According to the UK Government, these designations mark the "largest sanctions package against Russia since 2022" which, according to Foreign Secretary David Lammy, "underscores the UK's commitment to Ukraine".  Amount the designations were producers of machine tools, electronics and dual-use goods for Russia's military who are predominately based in third countries, including Central Asian states, Turkey, and China.  13 designations have also been made against Russian targets who have been cited as companies which are being used to funnel advanced European technology into Russia to support the war.  Read more>> and Read more>>
• OFSI issues General License on membership fees for international organisations: On February 21, OFSI issued General License INT/2025/5855272, which authorises certain International Organisations to receive subscription fees and any other payments required from the Government of Russia to retain membership of those organisations, subject to certain conditions, including that the funds are transferred from an account held with Gazprombank.  The International Organisations are trade organisations based in the UK with recognised diplomatic status, and include the International Renewable Energy Agency, the International Sugar Organisation and the North Atlantic Salmon Conservation Organisation. The General License expires on 20 February 2030.  Read more>>
• UK Government updates guidance on public sector contracts with suppliers from Russia and Belarus: On February 18, the UK Government updated Procurement Policy Note 007 (“PPN”) and related FAQs relating to public sector contracts with suppliers from Russia and Belarus.  Among other things, the PPN states that in-scope organisations should inter alia consider terminating contracts where a Russian or Belarusian prime contractor is identified and where a feasible alternative supplier can be sourced.  Read more>> and Read more>>
• UK Government adds five entries to and amends one entry on the UK sanctions list under the Russia regime: On February 14, OFSI added five entries to and amended one entry on the UK sanctions list under the Russia regime.  According to the UK Government, these sanctions target high profile figures working in the Russian Government and supporters of Russian state-owned business, including Pavel Fradkov, a Russian Defence Minister, Vladimir Selin, who heads up an arm of the Russian Ministry of Defence, and Artem Chaika, whose extractives company supports Russian state-owned business. Read more>> and Read more>>
• UK Government updates oil price cap general licence: On February 13, OFSI updated General licence INT/2024/4423849 to add CN / HS commodity code 2710 1944 under “premium to crude”.  At the same time, OFSI updated its guidance on the UK Maritime Services Ban and Oil Price Cap exception.  Read more>>, Read more>> and Read more>>
• UK Government publishes Financial Services Threat Assessment Report: On February 13, OFSI published its Financial Services Threat Assessment Report, one in a series of sector-specific assessments addressing threats to UK financial sanctions compliance.  The report identifies key evasion threats, red flags that businesses should be aware of, and recommendations on how to mitigate the identified risks. Read more>>
• UK Government calls for expressions of interest to conduct review of evidence on sanctions: On February 13, the UK Government invited expressions of interest from organisations to commission a theory-building systematic review of the research literature on the circumstances in which autonomous targeted sanctions, and other diplomatic measures, are effective in preventing conflict and atrocity in low- and middle-income countries.  The funding offered to eligible organisations is between £10,001 and £100,000 and organisations are required to respond by February 28, 2025. Read more>>
• SRA publishes guidance on trade sanctions for legal sector: On February 5, the Solicitor’s Regulation Authority issued guidance on trade sanctions.  The guidance sets out key risks for the legal sector, including areas of legal work that would be affected by trade sanctions.  Read more>>
• UK Court of Appeal revokes anti-suit injunction against RusChemAlliance at UniCredit’s request: On February 11, the UK Court of Appeal granted UniCredit’s request to lift an anti-suit injunction ("ASI") it won against RusChemAlliance ("RCA"), a Gazprom joint venture, after the bank said it wanted to avoid an “eye-watering” fine from the Russian courts.  UniCredit originally obtained the ASI in January 2024 in response to RCA commencing proceedings against it in the Russian courts, in contravention of the arbitration clauses in the relevant contracts between the parties.  However, in December 2024, the Russian courts granted RCA its own ASI against UniCredit and threatened to fine UniCredit EUR 250 million if it did not cancel the UK ASI, thus increasing UniCredit's potential liability from the EUR 460 million that RCA was seeking in its Russian lawsuit to EUR 710 million.  The Court found that UniCredit’s application should be granted for four reasons: (i) UniCredit is a commercial party acting in its own interests and is entitled to tell the court it no longer needs or wants the anti-suit injunction it had previously sought and obtained, (ii) the fact that UniCredit is acting under commercial pressure is not a weighty factor in favour of refusing the order it seeks, (iii) the public policy reasons against making the order that UniCredit seeks also do not weigh heavily in the balance, and (iv) in those circumstances, it would be unjust and unfair to force UniCredit to risk massive penalties in Russia that may be avoidable if the CA’s Order is discharged or varied. Read more>>
• UK Government removes one entry from the UK sanctions list under the Russia regime: On February 10, OFSI removed Irina Vladimirovna Chubarova, the head of corporate finance at Gazprom Neft PJSC, from the UK sanctions list under the Russia regime. Read more>>
• UK Foreign Affairs Committee holds oral evidence session: On February 4, the UK Foreign Affairs Committee held a one-off oral evidence session on the UK’s sanctions strategy. The evidence session examined the UK’s sanctions policy and the effectiveness of the UK’s sanctions regime.  Tom Keatinge (RUSI), Maya Lester KC (Brick Court Chambers), and Freya Page (Kharon) each submitted evidence to the committee. Read more>>
• Treasury Select Committee raises questions on HMRC’s role in enforcing trade sanctions: On January 31, 2025, Chair of the Treasury Select Committee, Dame Meg Hiller, wrote a letter to the chief executive of HMRC, Sir Jim Harra, posing ten questions about HMRC’s role in enforcing trade sanctions.  The questions arose from a previous oral evidence session on the work of OFSI held by the Treasury Select Committee in November 2024.  A response has been requested by February 17, 2025. Read more>>
• UK Government removes one entry from the UK sanctions list under the Russia regime: On January 30, OFSI removed Nikolay Ivanovich Bortsov from the UK sanctions list under the Russia regime.  Nikolay Ivanovich Bortsov was a former Russia politician who sat in the State Duma before passing away in 2023.  Read more>>
• OFSI Amends General Licence Relating to the Oil Price Cap: On January 29, OFSI amended General Licence INT/2024/4423849, which permits the provision of certain services in relation to Russian oil or oil products subject to certain conditions, including compliance with the oil price cap and certain record-keeping and attestation requirements.  The amendment to the General Licence updated Combined Nomenclature (CN) / Harmonized System (HS) commodity code for "Premium to Crude" which now falls under the commodity code "2710 19 42." Read more>> and Read more>>
• UK High Court awards Google final anti-enforcement injunctions against Russian media outlets: In a judgment handed down on 22 January 2025 in Google LLC & Google Ireland Limited v. NAO Tsargrad Media & others [2025] EWHC 94 (Comm), the UK High Court upheld claims for final anti-enforcement (and ancillary anti-anti-suit) injunctive relief against three Russian-domiciled defendants after an expedited trial of four actions commenced in mid-August 2024.  Russian media outlets NAO Tsargrad Media, TV-Novosti, and NO Fond Pravoslavnogo Televideniya had previously obtained Russian judgments after their YouTube channels were terminated for compliance with sanctions.  The Russian judgments led to seizure of over £51.2 million in Google Russia assets. The High Court found that recent attempts to enforce abroad were ‘exorbitant’, with claimed penalties reaching ‘£1,850,000,000,000,000,000,000,000,000,’ which the court noted ‘is about 20 trillion times greater than the estimated GDP of all the economies in the world.’ Read more>> and Read more>>
• UK Foreign Affairs Committee to hold one-off oral evidence session: On February 4, the UK Foreign Affairs Committee will hold a one-off oral evidence session on the UK’s sanctions strategy at 2pm. The evidence session will examine the UK’s sanctions policy in full and the effectiveness of the different sanctions regime.  Tom Keatinge (RUSI), Maya Lester KC (Brick Court Chambers), and Freya Page (Kharon) will appear to give evidence. Read more>> and Read more>>

IV.  Russia/Ukraine Sanctions

• Russia imposes sanctions against Norwegian news outlet: On February 7, Russia designated the Norwegian online news publication The Barents Observer.  The Russian Prosecutor's Office coined the organisation as "undesirable" for publishing "anti-Russian" content which has supposedly been written by exiled Russian citizens who are "listed as foreign agents or terrorists and extremists".  They further stated that the "articles are aimed at stirring dissent among residents of Russia’s northern regions, tightening anti-Russian sanctions and increasing NATO’s military presence near our borders". Read more>>
• Ukraine imposes sanctions against 56 Russian citizens: On February 5, Zelenskyy passed Decree No. 67/2025 which imposed sanctions against 56 Russian citizens and one Iranian citizen.  The designated individuals are captains of vessels of the Russian shadow fleet and are involved in the export of Russian oil bypassing the price ceiling.  Decree No. 67/2025 principally concerns individuals and entities responsible for the destruction of Ukrainian cultural identity through illegal archaeological excavations in the temporarily occupied Crimea and the export of cultural property from Ukraine.  Among the designations was the First Deputy Minister of Culture Sergei Obryvalin, Deputy Minister Vladimir Osintsev and President of the Union of Museums of Russia.  Read more>>

V.  Other Notable Developments

• Canada Sanctions Russia’s “Shadow Fleet”: On February 25, Canada announced new sanctions against Russia's “Shadow fleet” for its alleged involvement in exporting illegal Russian oil to global markets. Canada also announced “new military support to help Ukraine secure lasting peace and defend its sovereignty.” Read more>>
• Australia and New Zealand Escalate Sanctions Against Russia: On February 24, for the third anniversary of the war in Ukraine, the Australian and New Zealand governments added 70 more Russian individuals and 79 companies determined to be involved in supporting the war to its growing sanctions list. Read more>>
• Switzerland Adopts 15^th EU Sanctions Package Against Russia: On February 12, Switzerland followed the European Union in adopting a new package of sanctions imposed against Russia, including measures against Russian courts. Read more>>