Russia/Ukraine Sanctions Update - Month of October

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

I. US SANCTIONS

• OFAC Sanctions Two Entities and Blocks Two Vessels that Used Price Cap Coalition Service Providers While Carrying Russian Crude Oil above the Coalition-Agreed Price Cap: On October 12, the Department of the Treasury imposed sanctions on two entities and identified as blocked property two vessels that used Price Cap Coalition service providers while carrying Russian crude oil above the Coalition-agreed price cap. The Price Cap Coalition includes Australia, Canada, the European Union, France, Germany, Italy, Japan, the United Kingdom, and the United States. Read more >>
• Commerce Department Adds 49 Entities to the Entity List for Providing Support to Russia’s Military and/or Defense Industrial Base: On October 6, the Department of Commerce’s Bureau of Industry and Security added 49 entities to its Entity List for providing support to Russia’s military and/or defense industrial base. Forty-two of the entries are based in the People’s Republic of China, with additional entities based in Estonia, Finland, Germany, India, Turkey, the United Arab Emirates, and the United Kingdom. These entities supplied Russian consignees connected to the Russian defense sector with US-origin integrated circuits, including those identified in “Tier 1” of the Common High Priority Items List, developed by the US and other international partners. Russia relies on these microelectronics for precision guidance systems in the missiles and drones it uses against civilian targets in its unlawful war in Ukraine. Read more >>
• OFAC Issues Russia-related General License: On October 12, OFAC issued General License 73, “Authorizing Limited Safety and Environmental Transactions Involving Certain Persons or Vessels.” General License 73 authorizes all transactions, prohibited by Executive Order 14024, that are ordinarily incident and necessary to the safe docking and anchoring of any of the blocked vessels listed within the license, the preservation of the health or safety of the crew of any of the blocked vessels; or emergency repairs of any of the blocked vessels or environmental mitigation or protection activities relating to any of the blocked vessels. Read more >>
• OFAC Issues Russia-related General License Authorizing Certain Energy Sector Transactions: On October 25, OFAC issued General License 8H, “Authorizing Transactions Related to Energy.” General License 8H authorizes transactions, prohibited by Executive Order 14024, for certain entities related to energy, through 12:01 a.m. eastern daylight time on May 1, 2024. Read more >>
• Price Cap Coalition Publishes New Advisory for the Maritime Oil Industry and Related Sectors: On October 12, the Price Cap Coalition also published a Coalition Advisory for the Maritime Oil Industry and Related Sectors. The Advisory, which is directed at both government and private sector actors involved in the maritime trade of crude oil and refined petroleum products, provides recommendations concerning specific best practices and reflects the Coalition’s commitment to promoting responsible practices in the industry, preventing, and disrupting sanctioned trade, and enhancing compliance with the price cap. Read more >>
• Acting Assistant Secretary of the Treasury Department Warns of ‘Decisive’ Response If Russia Sells Oil Outside Price Cap or G7 Service Providers: On October 16, 2023, the Treasury Department’s Acting Assistant Secretary for Economic Policy, Eric Van Nostrand, warned that any attempts by Russia to sell oil above the oil price cap or sell crude without G7 involvement will trigger a “decisive and unified response.” Read more >> and Read more >>
• Secretary of the Treasury Department Participates in Fourth Ukraine Ministerial Roundtable: On October 11, Secretary of the Treasury, Janet L. Yellen, participated in the Fourth Ukraine Ministerial Roundtable. The Roundtable was chaired by Finance Minister of Ukraine, Sergii Marchenko, the International Monetary Fund (IMF) Managing Director, Kristalina Georgieva, and World Bank President, Ajay Banga. The Roundtable has been a valuable forum for Ministers from key donors and leaders of international financial institutions to gather during the semiannual IMF and World Bank meetings to demonstrate international support for Ukraine’s economy as it responds to Russia’s brutal aggression. Read more >>
• Justice Department Files Civil Forfeiture Complaint Against $300 Million Superyacht: On October 23, the Department of Justice filed a civil forfeiture complaint in the Southern District of New York against the motor yacht Amadea – a 348-foot luxury vessel reportedly worth more than $300 million and beneficially owned by sanctioned Russian oligarch, Suleiman Kerimov, which was seized in 2022 at the request of the United States. The filing alleged that the superyacht was improved and maintained in violation of applicable sanctions against Kerimov and those acting on his behalf. Read more >>
• President of Metalhouse LLC Pleads Guilty to Conspiracy to Launder over $150 Million to Promote Russian Sanctions Violations: On October 3, John Can Unsalan, the president of Metalhouse LLC, pleaded guilty in the US District Court for the Middle District of Florida for engaging in a conspiracy to commit money laundering to promote violations of US sanctions by conducting transactions to acquire over $150 million in metal products from companies owned by Sergey Kurchenko, a sanctioned Russian oligarch. Kurchenko was sanctioned by OFAC in 2015 for his role in misappropriating state assets of Ukraine or of an economically significant entity in Ukraine. Read more >>

II. EU SANCTIONS

• EU's General Court Decided That EU Sanctions on Olga Ayziman Should Be Lifted: On October 25, the General Court ruled that sanctions against Olga Ayziman, ex-wife of Mikhail Fridman, founder and one of the main shareholders of the Alfa Group, which includes the major Russian bank Alfa Bank, should be lifted since it could not be established that Olga Ayziman was associated with her ex-husband on the date of the adoption of sanctions. Read more >>
• EU Extends Sanctions on Broadcasting Activities: On September 29, Council Decision (CFSP) 2023/2097 extended sanctions on broadcasting activities in the EU, or directed at the EU, to media outlets such as RT Balkan, Oriental Review, Tsargrad, New Eastern Outlook, Katehon. Read more >>
• Council Publishes a Corrigendum to Council Implementing Regulation (EU) 2022/581 and Council Decision (CFSP) 2022/582: On October 24, the Council published a corrigendum to Council Implementing Regulation (EU) 2022/581 and Council Decision (CFSP) 2022/582 amending date of birth of Irina Anatolievna Kostenko. Read more >> and Read more >>
• Council Implementing Decision Extending Temporary Protection Given to Persons Displaced from Ukraine: On October 24, the Council published Decision (EU) 2023/2409 extending until 4 March 2025 the temporary protection given in Member States to persons displaced from Ukraine. Read more >>
• EU Updates List of Economically Critical Goods: On October 18, the EU updated its economically critical goods list, which details items that should be subject to enhanced due diligence to avoid diversion to Russia. Goods included in the list derive from selected groups of mainly industrial goods classified under HS chapters 28 (Chemicals), 84 (Machinery), 85 (Electronics) and 87 (Vehicles). Read more >>
• European Commission Updated Its Russia Sanctions FAQs on Imports, Purchase and Transfer of Listed Goods: On October 2, the European Commission updated its FAQ regarding Articles 3g, 3i, 3m and 3o of Council Regulation (EU) No 833/2014. Read more >>
• European Commission Updated Its Russia Sanctions FAQs on Export-Related Restrictions for Dual-Use Goods and Advanced Technologies: On October 2, the European Commission updated its FAQ regarding Articles 2, 2a and 2b of Council Regulation No 833/2014. Read more >>
• European Commission Updated Its Russia Sanctions FAQs on State-owned Enterprises: On October 23, the European Commission updated its FAQ regarding the prohibition to engage with certain state-owned enterprises. Read more >>
• EU Working On 12^th Sanctions Package: G7 ban on imports of Russian diamonds expected by the end of October is likely to be followed by a proposal for the EU's 12^th package of sanctions on Russia. According to informal sources, on top of the work on diamonds within G7, the new sanctions package is expected to reflect discussions on aluminum, dual-use goods, and measures to counteract circumvention of sanctions. Read more >> and Read more >>
• EU Imports Critical Raw Materials from Russia: Critical raw materials continue to flow freely from Russia to Europe in vast quantities, providing crucial funds to state enterprises and Russian businesses. According to Eurostat and the EU’s Joint Research Centre, between March 2022 and July 2023, Europe imported €13.7 billion worth of critical raw materials from Russia. More than €3.7 billion arrived between January and July 2023, including €1.2 billion of nickel. The European Policy Centre estimates that up to 90 per cent of some types of nickel used in Europe comes from Russian suppliers. Read more >>
• EU Welcomes the Alignment of Certain Countries with Council Decision Extending EU Sanctions against Russia for a Further Six Months: On October 11, the EU welcomed alignment of North Macedonia, Montenegro, Albania and Bosnia and Herzegovina, as well as of Iceland, Liechtenstein and Norway with the EU decision to renew its sanctions framework providing for asset freeze measures in view of Russia’s actions destabilizing the situation in Ukraine until 15 March 2024. Those countries also aligned with the EU's list of sanctioned persons. Read more >>
• EU Welcomes the Alignment of Certain Countries with Its Decision to Extend Sanctions on Broadcasting Activities: On October 23, the EU welcomed alignment of North Macedonia, Montenegro, Albania, Ukraine and Bosnia and Herzegovina, as well as of Iceland and Liechtenstein with the EU decision to extend sanctions on broadcasting activities to media outlets such as RT Balkan, Oriental Review, Tsargrad, New Eastern Outlook, Katehon. Read more >>
• Price Cap Coalition Statement on Actions Taken to Enforce Price Caps for Seaborne Russian-Origin Oil and Petroleum Products: On October 12, members of the Price Cap Coalition, consisting of G7 countries, Australia and the EU, issued a statement on actions taken to enforce price cap for seaborne Russian oil and petroleum products. Read more >>
• Price Cap Coalition Advisory for the Maritime Oil Industry and Related Sectors: On October 12, the Price Cap Coalition issued a Maritime Oil Industry Advisory directed to both government and private sector actors involved in the trading of seaborne crude oil and refined petroleum products. The Advisory outlines certain risks created by sanctions evasion as well as best practices that industry stakeholders are encouraged to adopt to reduce their exposure to possible risks associated with recent developments in the maritime oil trade. Read more >>
• European Commission Emphasizes That 'No-Claims Clause' Protects Operators Complying with EU Sanctions: On October 13, the European Commission explained that a ‘no-claims clause’ included as a standard provision in EU sanctions legislations protects operators required to comply with EU sanctions from having to satisfy claims brought forward by Russian and listed persons, or by persons acting through those persons or on their behalf, whenever those claims are connected with the performance of a contract or transaction affected by EU sanctions. Read more >> and Read more >>
• European Commission Explains That General Trade Statistics Should Not Be Used to Detect Breach of Sanctions: On October 25, the European Commission responded to a question pointing at an increase of imports in value by Austria from Russia, stating that general trade statistics mixing products subject to restrictions and those which are not, should not be used as an indicator of a possible breach of sanctions per se. It also noted that during the year 2022, there has been a substantial increase in prices for the imports of some goods, notably energy and raw materials, driven up by Russia’s aggression. Read more >> and Read more >>
• G7 Officials Backed European Efforts to Use Frozen Russian Assets: On October 13, representatives of the G7 issued a common statement at the World Bank-IMF conference in Marrakech, announcing that they would consider ways to spend proceeds from frozen Russian assets for Ukraine’s reconstruction. This announcement came a day after US Treasury Secretary Janet Yellen said that US want billions from Russia's immobilized assets to go to Ukraine. In October, Belgium, where most frozen Russian central bank assets are held, announced it expects to collect 2.3 billion euros in taxes on those assets and use them to help reconstruct Ukraine. The 'Russian Elites, Proxies, and Oligarchs (REPO) Task Force', which includes the EU, G7 and Australia, said in March 2023 that it has blocked or frozen more than $58 billion worth of sanctioned Russians’ assets. Read more >>
• Call On Agreement Allowing the Confiscation of Russian Public Assets Frozen by EU Sanctions: The Socialists and Democrats of the European Parliament called on the Member States to agree on a legal basis to allow the confiscation of Russian public assets frozen by EU sanctions for the purpose of the reconstruction of Ukraine. Read more >>
• European Parliament Endorses a Proposal for a Facility to Support Ukraine's Recovery: On October 5, the European Parliament endorsed a proposal for the ‘Ukraine Facility’. After the plenary vote on October 17, matter was referred back to the committee responsible within the European Parliament. Read more >> and Read more >>
• European Court of Auditors Issues an Opinion Concerning a Proposal for a Facility to Support Ukraine's Recovery: On October 5, EU auditors expressed their views on the proposal to establish a dedicated financing instrument, the ‘Ukraine Facility’, which would provide up to €50 billion over the 2024-2027 period to support Ukraine’s efforts to recover, reconstruct and modernize. The Court suggested enabling the European Commission to request that Ukraine review and/or modify the Ukraine Plan and backing loans to Ukraine with additional safeguards. Read more >>

III. UK SANCTIONS

• UK Government Updates UK Sanctions List under Russian Sanctions: On October 26, 2023, the UK Government made two administrative amendments under the Russia sanctions regime to update the listings for Veniamin Ivanovich Kondratyev and Nikolai Fyodorovna Kondratyuk. Both of these individuals remain subject to an asset freeze, travel ban, and trust services sanctions. Read more >>
• New OFSI General Licence for Legal Services Coming into Force: On October 25, 2023, OFSI announced that the new General Licence INT/2023/3744968 for Legal services will replace the current licence INT/2023/2954852 from October 29, 2023. The new licence makes several changes to rules governing the provision of legal services, most notably in respect of professional legal fees and expenses caps. The licence also sets out certain requirements for the reporting of legal services. Read more >>
• OFSI Amends General Licence for Payments to Companies House: On October 19, 2023, OFSI amended General Licence INT/2023/3626884, under which UK assets freeze targets are authorised to make certain payments to Companies House. Most notably, the amendment updates the definition of Permitted Payments to include the payment of penalty fees relating to the late filing of annual accounts by those asset freeze targets. Read more >>
• UK ECJU Amends Export Control Order 2008: On October 17, 2023, the UK Government published a notice stating that the Export Control (Amendment) (No 2) Regulations 2023 will come into force on 23 October 2023. These regulation amends the Export Control Order 2008 to (i) remove Syria from Part 2 of Schedule 4 and (ii) correct two drafting errors in the retained Dual-Use Regulation. Read more >>
• UK Government Publishes Guidance on the Interception and Monitoring Prohibitions in UK Sanctions: On October 17, 2023, the UK Government published guidance on the interception and monitoring prohibitions in UK sanctions on Russia, Belarus, Myanmar (Burma), Iran, Syria and Venezuela. The guidance provides further information on the meaning of 14 specific terms used in the scheduled to the relevant regulations. Read more >>
• UK Government Considering Impact of Court of Appeal Judgment in Mints Case: On October 16, 2023, the FCDO published a statement that it was considering the impact of the Court of Appeal’s judgment in Mints & others v. PJSC National Bank Trust & another, in particular the Court’s views that PJSC National Bank Trust is ‘controlled’ by Designated Persons by virtue of their political office. Among other things, the FCDO stated that there is no presumption on the part of the UK Government that a private entity based in or incorporated in Russia or any jurisdiction in which a public official is designated is in itself sufficient evidence to demonstrate that the relevant official exercises control over that entity. On 22 November 2023, a webinar featuring speakers from inter alia FCDO and OFSI will take place to discuss ownership and control under UK sanctions and the Government’s statement following the Mints judgment. Read more >>
• OFSI Amends General Licence for Payment to Energy Companies: On October 13, 2023, OFSI amended General Licence INT/2022/2300292 inter alia to allow an individual or company to make certain payments to energy companies for or on behalf of a designated person. Read more >>
• UK Court of Appeal Grants Anti-Suit Injunction Preventing Russian Proceedings in Sanctions Case: On October 11, 2023, the Court of Appeal allowed an appeal by Deutsche Bank and granted an anti-suit injunction against the proceedings brought by RusChemAlliance LLC in Russia. The dispute concerned non-payment by Deutsche Bank under a guarantee due to the application of EU sanctions. The Court granted the anti-suit injunction on the following grounds: (i) the guarantee contract stated that disputes were to be settled by arbitration in Paris under the ICC rules of arbitration, (ii) the English application was not contrary to French public policy on anti-suit injunctions, (iii) the English court was the proper place to bring the claim, and (iv) there was no good reason not to award the anti-suit injunction. Read more >>
• OFSI Extends and Amends Prior Obligations General Licence: On October 10, 2023, OFSI extended General Licence INT/2023/3024200 for a further 6 months, until 21 May 2024. The General Licence permits UK persons who are owed funds or economic resources by a designated person under a contract that was signed prior to that person’s designation to receive the relevant funds or economic resources, subject to certain conditions. The General Licence was also amended to change certain definitions, terms and permissions relating to payments caught by the licence. Read more >>
• UK Government Issues General Licence for Payments to Companies House: On October 6, 2023, the UK Government issued General Licence INT/2023/3626884, which allows, among other things, designated persons to make permitted payments to Companies House and UK financial institutions to process such payments. Read more >>
• UK Court of Appeal Dismisses Appeal in Sanctions Case, and Comments on “Control” Test in Obiter Comments: On October 6, 2023, the Court of Appeal handed down judgment in Boris Mints & Ors v. PJSC National Bank Trust & Anor [2023] EWCA Civ 1132, a case that concerns the interaction between the UK Russia sanctions regime and ongoing litigation involving designated persons. Among other things, the Court of Appeal held that: (i) UK sanctions regulations do not preclude a designated person (“DP”) or the court from giving a money judgment (and so the appeal for a stay of proceedings was rejected), nor do they displace the right of a designated person’s access to the English court system; (ii) a cause of action is an economic resource, but not a fund; and (iii) OFSI can licence an adverse costs order both for or against a DP. In its obiter, the Court of Appeal also made comments on the control test under UK sanctions regulations: among other things, it considered that the court at first instance was incorrect in stating that there was a carve out from the control test for control by political office and that the concept of control covered any persons who, for whatever reason, is able to exercise control over another company irrespective of whether the DP has an ownership interest in the other company, economic or otherwise. Read more >> and Read more >>
• UK Government Issues General Licence for Correspondent Banking Payments: On September 29, 2023, OFSI issued General licence INT/2023/3566356, which authorises a Credit or Financial Institution to return a “Relevant Payment” subject to certain conditions. The general licence appears to be addressing a scenario where a DP bank is not a direct counterparty to a UK financial institution, but further upstream in the payment chain. Read more >>

IV. RUSSIA/UKRAINE SANCTIONS

• G7 Announcement on Russian Diamond Ban Expected by End October: According to the diplomatic sources, a G7 statement announcing a ban on imports of Russian diamonds is expected by the end of this month, followed closely by a proposal for the European Union's 12^th package of sanctions on Russia. The statement was expected to arrive within a week. The EU's 12^th sanctions package is expected to focus on Russian diamonds. The G7 held a technical meeting last week to discuss several proposals put forward by India, industry groups and Belgium. Read more >>
• Deutsche Bank Admits that Its Russian Assets Might Be Confiscated: Deutsche Bank admitted that it could not repay the debt to Gazprom’s subsidiary, the Ruskhimalliance company. The debt arose due to an outstanding advance payment, which “the bank cannot fulfill due to EU sanctions against Russia”. The Russian courts do not recognize EU sanctions as a ground for non-payment. Deutsche Bank reported that it had created reserves of almost 260 million euros for the possible nationalization of its assets in Russia. Read more >>
• Ukraine Excluded the OTP Bank and an Indian Producer of Diamonds from the List of Sponsors of the War: The National Anti-Corruption Agency of Ukraine has removed the Hungarian OTP Bank and one of the world's largest diamond production and export company, India's Shree Ramkrishna Exports (SRK), from the list of international war sponsors. The Agency explained that OTP Bank made a number of commitments regarding its future plans on the Russian market and Shree Ramkrishna Exports issued an official statement, stating that it will comply with international obligations and will not cooperate with Russian sanctioned entities. Read more >> and Read more >>
• Belgium Plans to Use Frozen Russian Assets for Support of Ukraine: Speaking in the press conference, the Belgian Prime Minister Alexander De Croo stated that Belgium had set up a €1.7 billion fund to help Ukraine as part of the new federal budget. The money is drawn from the taxation of Russian assets that are frozen within the Euroclear banking platform, which is located in Brussels. "I hope that these measures can be a source of inspiration for the other countries of the European Union," De Croo added. Read more >>
• Russia Files a Complaint to ICAO against the EU and US: On 10 October Russia has filed a complaint with the International Civil Aviation Organization (ICAO, a UN agency) against 37 countries for closing their skies to Russian airlines and imposing sanctions against Russian aviation. According to Russia, these states violated the provisions of the Chicago Convention, among the provisions of which are to meet the needs of the peoples of the world for safe and economical air transport, avoid discrimination against states parties to the convention and promote flight safety. The Foreign Ministry saw a violation of these principles in the actions of the United States, all EU countries, Great Britain, Canada, Switzerland, Iceland and a number of other European states. Read more >>
• China Saves Billions of Dollars from Record Sanctioned Oil Imports: China has reaped savings this year of nearly $10 billion through record purchases of oil from countries under Western sanctions. An unintended consequence of sanctions imposed by the United States and others on Russia, Iran and Venezuela has been to lower the oil import costs for refiners in top economic rival China, which often criticises such "unilateral" penalties. China's purchases are also a revenue lifeline for Moscow, Tehran and Caracas, whose economies are otherwise curtailed by Western sanctions and a decline in investment. Read more >>
• Kazakhstan has Banned the Supply of 106 Military Goods to Russia: Drones, chips and other military goods will be prohibited from being supplied to Russia, announced the Kazakh government. “The main problem is related to exports. We export all goods [through Russian territory]. The export of only war-related goods was limited,” said Vice Minister of Trade and Integration Kairat Torebayev. In the spring, the United States warned of growing risks for Kazakhstan to be subject to secondary sanctions due to Russia's attempts to circumvent Western restrictive measures. Read more >>
• EBRD Got an Approval for the Sale of a 5.3% Stake in Moscow Exchange: The authorities have approved the sale of a 5.3% stake in the Moscow Exchange owned by the European Bank for Reconstruction and Development (EBRD) to the Softline group of companies. The EBRD, which entered the capital of Moscow Exchange in 2012, is selling a 5.3% stake in Softline at a 60% discount and a 20% exit tax. According to the publication, the EBRD may ultimately receive no more than $76.3 million for the asset. Read more >>
• The Russian Court Invalidates a Sale of the Russian Assets of an EU Company Due to the Lack of Permission from the Russian Authorities: The Moscow District Arbitration Court invalidated the deal between businessman Ruslan Prudnikov and the construction company Bauer Technology due to the lack of permission from the government commission for control of foreign investments. This is the first such decision that has become publicly known. In the summer of 2022, Bauer Technology sold land and real estate to individual entrepreneur Ruslan Prudnikov. The case files say that Bauer Technology did not apply to the Russian Investment Commission for permission before completion of the deal. Read more >>
• Aeroflot Has Settled a Dispute with an Irish Lessor over 17 Aircraft: Aeroflot Group has completed the process of resolving a dispute with the Irish lessor SMBC Aviation Capital regarding 17 aircraft. The 17 aircraft leased by the Aeroflot group from the Irish SMBC Aviation Capital became the property of the insurance company NSK, which paid the settlement amount. It is noted that Aeroflot continues negotiations on settling relations with other lessors of foreign-made aircraft. Read more >>
• The Russian Government Decided to Sell Exxon's Stake in Sakhalin-1 to a Russian Company: The Russian government has approved the rules for the assessment and sale of the “unclaimed” share (30%) of the American Exxon Neftegaz Limited (a subsidiary of ExxonMobil) in the authorized capital of the operator of the Sakhalin-1 oil and gas project. The corresponding decree was signed by the Russian Prime Minister Mikhail Mishustin on 28 September. The Federal Property Management Agency will ensure the sale of a stake in the authorized capital of Sakhalin-1 LLC. A Russian legal entity that meets the criteria approved by the Russian government can participate in bidding. Read more >>
• Export Blockade Threatens Ukraine's Steel Industry: It is reported that Ukraine’s steel industry, which makes up around 10% of Ukraine’s GDP, has suffered enormous losses due to the Russian blockade of the Black Sea. Since 2021, exports of steel from Ukraine have shrunk by more than 80%, largely due to the blockade and the fact that many of the biggest plants are situated in now Russian-occupied parts of the country. Read more >> and Read more >>
• Russia's Federation Council Approves Bill to Revoke Ratification of Nuclear Test Ban Treaty: On October 25, 2023, the Federation Council, which is the upper chamber of the Russian parliament, has voted in favour of legislation to revoke Moscow’s ratification of the Comprehensive Nuclear-Test-Ban Treaty. The decision was approved by 156 votes to zero, the final stage before it goes to President Vladimir Putin for signing. Putin had called for the action to mirror the position of the United States, which signed but never ratified the treaty. Read more >> and Read more >>
• Russia Adds Ex-Russian Deputy Foreign Minister and Political Scientist to 'Foreign Agent' List: On October 21, 2023, Russia's Justice Ministry added Georgy Kunadze, Russia’s former Deputy Foreign Minister and editor in chief of news website Ilya Kosygin, and political scientist and rights activist Mikhail Savva to its list of so-called foreign agents. Kunadze is accused of allegedly disseminating “false information aimed at creating a negative image about the Russian Federation”. Savva is an expert at the Ukrainian Center for Civil Liberties. Read more >>

V. OTHER NOTABLE DEVELOPMENTS

• The US, Australia, Canada, New Zealand, and United Kingdom Release Joint Guidance on Countering Russia Evasion: On September 26, the governments of Australia, Canada, New Zealand, the United Kingdom, and the United States issued joint guidance to industry and academia identifying high priority items critical to Russian weapons systems and urging specific actions to prevent diversion of these items to Russia through third countries. The guidance identifies 45 categories of items deemed critical for Russian weapons development. Read more >>
• Russian Oligarch Asks Court to Render Australia’s Sanctions Regime Invalid: Russian oligarch, Oleg Deripaska, challenged sanctions imposed on him by the Australian government for his alleged links to Vladimir Putin. Australia imposed sanctions on Deripaska in March of 2022, a move that prevented him from travelling to Australia or profiting from his company’s stake in an alumina refinery in Gladstone, Queensland. Read more >>
• Switzerland Tightens Sanctions over Iranian Drone Deliveries to Russia: On September 29, Switzerland adopted further sanctions in connection with Iran's drone deliveries to Russia. Switzerland’s Federal Council announced the sale, supply, export, and transit of components used for the manufacture and production of drones is now prohibited. Switzerland also issued targeted financial and travel sanctions against persons and entities connected with support for Iran's drone program. Read more >>
• UN General Assembly Rejects Russia's Bid to Regain Seat on Human Rights Council: On October 10, 2023, the UN General Assembly voted to reject Russia’s bid to regain its seat on the United Nations Human Rights Council. A secret ballot was held for the Council’s 2024-2026 term and Russia won 83 votes, compared with 160 for Bulgaria and 123 for Albania, to whom the final two seats were given. Read more >>
• Belgium Expect to Use $2.4 Billion in Tax on Frozen Russian Assets to Fund Ukraine: On October 11, 2023, a spokesperson for the Belgian Prime Minister announced that Belgium is expecting to collect around $2.4 billion in taxes on frozen Russian assets and use them to help reconstruct Ukraine. Read more >> and Read more >>
• Canada Sanctions Russian Collaborators in Moldova: On October 16, Canada imposed sanctions on 9 individuals, including those who are associated with influential oligarchs or connected to the Shor Party, and six television stations that Moldovan authorities have found actively promoted and disseminated Russian disinformation to justify Russia’s war of aggression against Ukraine. Read more >>
• Bulgaria Defends Decision to Impose Tax on Russian Gas Transit as Hungary and Serbia Vow to Respond: On October 18, 2023, the Bulgarian Government defended its decision to impose a new tax on Russian gas being transported through Bulgaria, the country’s Prime Minister, Nikolay Denkov, commenting that the increased tax would create competition in the gas market and that Europe would benefit from it. Both Hungary and Serbia, who are reliant on gas supplies from Russia, have vowed to respond to the move, which they called a “hostile” step. Bulgaria imposed a tax on Russian gas transit in the amount of 20 leva ($10.80) per megawatt-hour on October 13. Read more >> and Read more >>
• Finland Blocks Russian Property Acquisitions over Defense Concerns: On October 19, 2023, Finland's Defense Ministry announced that it had blocked three planned property transactions involving Russian buyers because they believe that, were the acquisitions allowed to take place, there could be risks to national defence. Read more >> and Read more >>