Update on new Norwegian sanctions against Russia

On 24 March 2022, Norway introduced further restrictive measures against Russia.

A copy of amending regulation (in Norwegian only) is accessible here. The regulation enters into force immediately. The amending regulation covers the restrictive measures adopted and published by the EU on 15 March 2022 (the EU's fourth package of restrictive measures).

In particular, it prohibits all transactions with certain Russian state-owned entities. It also prohibits the provision of any credit rating services, as well as access to any subscription services in relation to credit rating activities. Furthermore, it prohibits new investments in the Russian energy sector, and introduces comprehensive export restrictions on equipment, technology and services for the energy industry in Russia. Moreover, it introduces further trade restrictions concerning iron and steel, as well as certain luxury goods.

The new adopted sanctions are the following:

As of 24 March 2022, it is prohibited to directly or indirectly engage in any transaction with the following Russian state-owned entities (as well as a legal person, established outside Norway or the EU whose proprietary rights are directly or indirectly owned for more than 50 % by the listed entity; or a legal person acting on behalf or at the direction of an listed entity):

• OPK Oboronprom


• United Aircraft Corporation


• Uralvagonzavod


• Rosneft


• Transneft


• Gazprom Neft


• Almaz-Antey


• Kamaz


• Rostec (Russian Technologies State Corporation)


• JSC PO Sevmash


• Sovcomflot


• United Shipbuilding Corporation

However, that prohibition does not apply to the execution until 24 May 2022 of contracts concluded before 25 March 2022 or ancillary contracts necessary for the execution of such contracts.

Moreover, that prohibition does not apply to:

• transactions which are strictly necessary for the purchase, import or transport of fossil fuels, in particular coal, oil and natural gas, as well as titanium, aluminium, copper, nickel, palladium and iron ore from or through Russia into Norway or the EU;


• transactions related to energy projects outside Russia in which abovementioned Russian state-owned entity is a minority shareholder.

As of 24 April 2022, it is prohibited to provide to any Russian national or natural person residing in Russia or any legal person established in Russia:

• credit rating services;


• access to any subscription services in relation to credit rating activities.

However, those prohibitions do not apply to nationals of Norway or a Member State of the EU or natural persons having a temporary or permanent residence permit in Norway or a Member State of the EU.

As of 24 March 2022, it is prohibited to sell, supply, transfer or export, directly or indirectly, certain goods or technology, whether or not originating in Norway, to any natural or legal person in Russia or for use in Russia, including its Exclusive Economic Zone and Continental Shelf.

It is also prohibited to provide directly or indirectly to any natural or legal person in Russia or for use in Russia:

• technical assistance, brokering services or other services related to those goods and technology; and to manufacture, maintenance and use of those goods and technology;


• financing or financial assistance related to those goods and technology for any sale, supply, transfer or export of those goods and technology, or for the provision of related technical assistance, brokering services or other services.

However, those prohibitions do not apply to goods or technology necessary for:

• the transport of fossil fuels, in particular coal, oil and natural gas, from or through Russia into Norway or the EU; or


• the urgent prevention or mitigation of an event likely to have a serious and significant impact on human health and safety or the environment.

Please note, that those prohibitions do not apply to the execution until 26 September 2022 for contracts concluded before 25 March 2022, or ancillary contracts necessary for the execution of such a contract. In such cases, the Norwegian Ministry of Foreign Affairs should be informed at least five working days in advance.

Furthermore, the Norwegian Ministry of Foreign Affairs may authorise the sale, supply, transfer or export and the provision of technical or financial assistance, if:

• it is necessary for ensuring critical energy supply within Norway or the EU; or


• it is intended for the exclusive use of entities owned, or solely or jointly controlled by a legal person which is incorporated or constituted under the law of Norway or a Member State of the EU.

As of 24 March 2022, it is prohibited to:

• acquire any new or extend any existing participation in any legal person, entity or body incorporated or constituted under the law of Russia or any other third country and operating in the energy sector in Russia;


• grant or be part of any arrangement to grant any new loan or credit or otherwise provide financing, including equity capital, to any legal person incorporated or constituted under the law of Russia or any other third country and operating in the energy sector in Russia, or for the documented purpose of financing such a legal person;


• create any new joint venture with any legal person, entity or body incorporated or constituted under the law of Russia or any other third country and operating in the energy sector in Russia;


• provide investment services directly related to the abovementioned activities.

However, the Norwegian Ministry of Foreign Affairs may authorise the sale, supply, transfer or export and the provision of technical or financial assistance, if:

• is necessary for ensuring critical energy supply within Norway or the EU, as well as the transport of fossil fuels, in particular coal, oil and natural gas, from or through Russia into Norway or the EU; or


• it exclusively concerns a legal person operating in the energy sector in Russia owned by a legal person, which is incorporated or constituted under the law of Norway or a Member State of the EU.

Please note, that energy sector means a sector covering the following activities with the exception of civil nuclear related activities:

• the exploration, production, distribution within Russia or mining of crude oil, natural gas or solid fossil fuels, the refining of fuels, the liquefaction of natural gas or regasification;


• the manufacture or distribution within Russia of solid fossil fuel products, refined petroleum products or gas; or


• the construction of facilities or installation of equipment for, or the provision of services, equipment or technology for, activities related to power generation or electricity production.

As of 24 March 2022, it is prohibited to:

• import, directly or indirectly, certain iron and steel products into Norway if they originated in Russia or have been exported from Russia;


• purchase, directly or indirectly, certain iron and steel products as listed which are located or which originated in Russia;


• transport certain iron and steel products if they originated in Russia or are being exported from Russia to any other country;

It is also prohibited to provide, directly or indirectly, technical assistance, brokering services, financing or financial assistance, including financial derivatives, as well as insurance and re-insurance, related to the abovementioned prohibitions.

Those prohibitions do not apply to the execution until 26 June 2022 of contracts concluded before 25 March 2022, or ancillary contracts necessary for the execution of such contracts.

As of 24 March 2022, it is prohibited to sell, supply, transfer or export, directly or indirectly, certain luxury goods of a value exceeding EUR 300 per item to any natural or legal person, or for use in Russia, including:

• Horses;
• Caviar and caviar substitutes;
• Truffles and preparations thereof;
• Wines (including sparkling wines), beers, spirits and spirituous beverages;
• Cigars and cigarillos;
• Perfumes, toilet waters and cosmetics, including beauty and make-up products;
• Leather, saddlery and travel goods, handbags and similar articles;
• Coats, or other garments, clothing accessories and shoes (regardless of their material);
• Carpets, rugs and tapestries, hand-made or not;
• Pearls, precious and semi-precious stones, articles of pearls, jewellery, gold or silversmith articles;
• Coins and banknotes, not being legal tender;
• Cutlery of precious metal or plated or clad with precious metal;
• Tableware of porcelain, china, stone- or earthenware or fine pottery;
• Items of lead crystal;
• Clocks and watches and their parts;
• Works of art, collectors' pieces and antiques;
• Articles and equipment for sports, including skiing, golf, diving and water sports;
• Articles and equipment for billiard, automatic bowling, casino games and games operated by coins or banknotes

• Electronic items for domestic use of a value exceeding EUR 750;
• Musical instruments of a value exceeding EUR 1 500;
• Electrical/electronic or optical apparatus for recording and reproducing sound and images of a value exceeding EUR 1 000;
• Vehicles, except ambulances, for the transport of persons on earth, air or sea of a value exceeding EUR 50 000 each, teleferics, chairlifts, ski-draglines, traction mechanisms for funiculars, motorbikes of a value exceeding EUR 5 000 each, as well as their accessories and spare parts;

That prohibition does not apply to luxury goods which are necessary for the official purposes of diplomatic or consular missions in Russia or of international organisations enjoying immunities in accordance with international law, or to the personal effects of their staff.

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Please note that those 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 those 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.