The key sanctions imposed throughout 2024 in response to Russia’s military activity in Ukraine, including the EU’s 15th package of economic and individual restrictive measures against Russian entities and individuals.
Russia’s continued military activity in Ukraine comes at a huge cost to life, finances, and diplomatic relations. The UK, US, EU and other countries have increasingly isolated Russia from financial markets in the West and imposed trade restrictions on high-value goods, including oil.
Amid ongoing sanctions regimes, companies must ensure they comply with multiple regimes whilst managing the impact on their operations. Difficult corporate decisions may be required, and potentially even loss of capital, to protect corporate reputation and prepare for more individuals and entities to be added to sanctions lists around the world.
To help companies stay up-to-date and ensure they are compliant, this article outlines the crucial sanctions imposed against Russia by key jurisdictions in 2024, along with countersanctions, and an analysis of the most recent updates. Click here to see the full 2023 timeline.
The situation in Ukraine is changing constantly, so we recommend consulting government and media outlets, and Lexology PRO’s automated regulatory monitoring tool, Scanner, for the most up-to-date information.
Analysis
Western allies are further clamping down on entities in third-party countries which are seen as facilitators of Russian sanctions evasion. On 16 December 2024 – in a first of its kind – the EU imposed sanctions including travel bans and asset freezes on Chinese actors supplying drone and electronic components in support of Russia’s military activity in Ukraine. This came after the US sanctioned 42 Chinese companies suspected of aiding Russian sanctions evasion on 23 August 2024. The EU’s 14th package of sanctions against Russia notably targeted “companies actively involved in circumventing EU sanctions through financial transactions and delivery of prohibited EU goods,” including a port operator involved in shipping weapons and ammunitions from North Korea to Russia.
Enforcement agencies are also seeing their powers over foreign businesses enhanced. For example, Swedish banks and other financial institutions must now report transfers from the EU to a country outside the EU to the Swedish Financial Supervisory Authority if the transfer comes from a Russian-owned company and exceeds €100,000 (US$103,000). On 31 July 2024 the UK foreign office received new powers to sanction foreign companies that provide financial services to parties that support or benefit from the Russian government. Doubts have been cast on the efficacy of Western sanctions to date in light of Russia’s trade relationships with China, North Korea and Iran. Further clampdown on potential routes for sanctions evasion are expected.
The first EU transfer of seized Russian funds to Ukraine came on 26 July 2024. This transfer is not only a positive step for helping Ukraine to access the materials and tools needed to continue military defence but also to help rebuild critical infrastructure devastated by the conflict. This move follows the G7 decision to provide a US$50 billion loan for Ukraine backed by confiscated Russian assets in June 2024. The US has been sending transfers since May 2023, and on 29 July 2024, for the first time in the UK, the National Crime Agency successfully secured the forfeiture of sanctioned funds under the Proceeds of Crime Act 2002.