Update: Norwegian sanctions against Russia

The new measures have been incorporated into Norwegian law through the amendments to the Regulation of 15 August 2014 no. 1076 on restrictive measures concerning actions that undermine or threaten Ukraine's territorial integrity, sovereignty, independency, and stability (Forskrift 15. august 2014 nr. 1076 om restriktive tiltak vedrørende handlinger som undergraver eller truer Ukrainas territorielle integritet, suverenitet, uavhengighet og stabilitet).

A copy of amending regulation (in Norwegian only) is accessible here. The regulation enters into force immediately. The regulation covers the restrictive measures adopted and published by the EU up to and including 2 March 2022, with the exception of the ban on media sector (such as broadcasting content from Russian media outlets RT and Sputnik).

The adopted sanctions target the financial, energy, transport, technology and defence sectors, and also impose asset freezes and travel bans on hundreds of individuals and entities.

The Government has also stated that it will continue to consider the adoption of further sanctions in line with the EU sanctions adopted after 2 March 2022.

With effect from 4 May 2022 the prohibitions against dealing with certain transferable securities and money market instrument as issued by specific entities will be extended. It will then generally be prohibited to deal with any transferable securities and money market instruments issued by any of the previously listed entities and by the following entities (including companies owned, controlled by, or acting on behalf of the same):

• Alfa Bank


• Bank Otkritie


• Bank Rossiya


• Promsvyazbank


• Almaz-Antey


• Kamaz


• Novorossiysk Commercial Sea Port


• Rostec (Russian Technologies State Corporation)


• Russian Railways


• JSC PO Sevmash


• Sovcomflot


• United Shipbuilding Corporation

Similarly, from 19 March 2022, the prohibition against making or being part of certain arrangements to make new loan or credit to specific entities, will generally apply to all loans or credit to such persons and to the above listed entities (i.e. without any minimum maturity threshold).

As of 28 March 2022, it is prohibited to provide SWIFT services to the following Russian banks, or any legal person, entity or body established in Russia whose proprietary rights are directly or indirectly owned for more than 50% of these Russian banks:

• Bank Otkritie


• Novikombank


• Promsvyazbank


• Bank Rossiya


• Sovcombank


• VNESHECONOMBANK (VEB)


• VTB BANK

Transactions related to the management of reserves as well as of assets of the Central Bank of Russia, including transactions with any legal person, entity or body acting on behalf of, or at the direction of, the Central Bank of Russia, are prohibited.

It is prohibited to directly or indirectly purchase or sell investment services or provide assistance in the issuance of, or any other dealing with transferable securities and money-market instruments issued after 1 April 2022 by:

• Russia and its Government;


• the Russian Central Bank; or,


• a legal person acting on behalf of or at the direction of the Russian Central Bank.

It is prohibited to directly or indirectly make, or be part of any arrangement to make, any new loans or credit after 18 March 2022 to

• the Russian Central Bank; or,


• a legal person acting on behalf of or at the direction of the Russian Central Bank.

This prohibition does not apply to loans or credit that have a specific and documented objective to provide financing for non-prohibited imports or exports of goods and non-financial services between Norway and any third State, including the expenditure for goods and services from another third State that is necessary for executing the export or import contracts.

It is prohibited to invest, participate or otherwise contribute to future projects co-financed by the Russian Direct Investment Fund.

The Norwegian Ministry of Foreign Affairs may authorise, under such conditions as they deem appropriate, an investment participation in, or contribution to, projects co-financed by the Russian Direct Investment Fund if the investment participation or contribution is due under contracts concluded before 18 March 2022 or ancillary contracts necessary for the execution of such contracts.

As of 18 March 2022, it is prohibited to sell, supply, transfer or export euro denominated banknotes to Russia or to any natural or legal person, entity or body in Russia, including the government and the Central Bank of Russia, or for use in Russia, except if it is necessary for:

• the personal use of natural persons travelling to Russia or members of their immediate families travelling with them;


• the official purposes of diplomatic missions, consular posts or international organisations in Russia enjoying immunities in accordance with international law.

It is prohibited to accept deposits from Russian nationals or natural persons residing in Russia, or legal persons, entities or bodies established in Russia, if the total value of deposits of the natural or legal person, entity or body per credit institution exceeds 100 000 EUR.

However, the prohibition does not apply:

• to nationals or natural persons having a temporary or permanent residence permit in Norway, EEA and Switzerland.


• to deposits which are necessary for non-prohibited cross-border trade in goods and services between the Norway and Russia that are not sanctioned;


• when authorisation is given by the Norwegian Ministry of Foreign Affairs.

It is prohibited to sell, supply, transfer or export, directly or indirectly, to Russia specific goods and technologies for use in oil refining. It also prohibited to provide technical assistance and other related services as well as financing and financial assistance in relation to the goods and technology subject to this prohibition.

However, the prohibition does not apply:

• for contracts concluded before 19 March 2022 with execution up to and including 22 June 2022;


• when authorisation is given by the Norwegian Ministry of Foreign Affairs.

It is prohibited for any aircraft operated by Russian air carriers, or for any non-Russian-registered aircraft which is owned or chartered, or otherwise controlled by any Russian natural or legal person, entity or body, to land in, take off from or overfly the territory of Norway, except for:

• emergency landing or an emergency overflight;


• when authorisation is given by the Norwegian Ministry of Foreign Affairs.

It is prohibited to sell, supply, transfer or export, directly or indirectly, to Russia certain goods and technologies suited for use in aviation and the space industry, as well as to provide insurance and reinsurance and maintenance services in relation to those goods and technology. It also prohibited to provide technical assistance and other related services as well as financing and financial assistance in relation to the goods and technology subject to such prohibition.

It is prohibited to sell, supply, transfer or export, directly or indirectly, to Russia certain goods and technology which might contribute to Russia’s technological enhancement of its defence and security sector. It also prohibited to provide technical assistance and other related services as well as financing and financial assistance in relation to the goods and technology subject to such prohibition.

The list of persons and entities covered by asset freezes and travel restrictions is updated in line with the EU's listings, including but not limited to :

• Persons participating in the actions of Belarus supporting the Russian aggression against Ukraine;


• Russian oligarchs and businesspeople operating in partnership with the Russian state, including e.g. Igor Sechin (CEOs of Rosneft), Nikolay Tokarev (CEO of Transneft) and Alisher Usmanov, Petr Aven, Mikhail Fridman, Alexey Mordaschov;


• Gas Industry Insurance Company SOGAZ.

It is prohibited to import into Norway goods originating in Donetsk and Luhansk. It is also prohibited to provide, directly or indirectly, financing or financial assistance, as well as insurance and reinsurance, related to the import of goods originating in Donetsk and Luhansk.

The Ministry of Foreign Affairs invited to an information meeting for businesses on 21 March 2022 concerning the implications of the adapted sanctions. The Ministry confirmed the continuance of the government's policy on adapting similar sanctions as the EU, and that recent EU-sanctions not yet in force under Norwegian law will be subject to enactment within one-two weeks. In particular, this concerns the EU-sanctions that were adapted on 15 March 2022.

From our perspective, we note that there is still a general need for further clarifications related to several of the Regulation's provisions, as the extent of many provisions are unclear. Schjødt will continue to analyse the provisions of the Regulation, and share the analysis and new developments with clients.

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Please note that these updates do not provide an exhaustive description of all sanctions in place, and they may not be construed as legal advice. It is a criminal offence for Norwegian citizens and companies, and other people and enterprises in Norway to violate these sanctions. Any person or entity involved in business activities in any way related to Russia, should carefully assess whether and how they are affected by the new sanctions. Schjødt's sanctions team is ready to assist in this regard.