Update on sanctions developments in connection with the invasion of Ukraine


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Norway has adopted the fifth sanction package from EU introduced on 8 April 2022. As of 7 May 2022, Norway will prohibit access to Russian-flagged vessels to Norwegian Ports. The new sanctions also prohibit Russian road transport undertakings to transport goods by road. The latter is already in effect with some exceptions for transport already initiated before 29 April 2022.

Access to Norwegian ports and transporting goods by road

The ban on access to Norwegian ports applies to Russian-flagged vessels (including vessels that have been registered with the Russian flag after 24 February 2022). The ban concerns commercial vessels weighing more than 500 gross tons as well as yachts and some recreational vessels. The ban does not apply to fishing vessels, rescue vessels, vessels used for researching purposes, and port calls due to emergency reasons (port of refuge and similar). The prohibition concerns Norwegian ports located on the mainland meaning that amongst others Svalbard and Jan Mayen are not included.

The road transport ban prohibits road transport undertakings (freight road operators) established in Russia from transporting goods by road within the territory of Norway. It does not apply to (i) the provision of mail as a universal service, (ii) vehicles that were already in the territory of the European Union on 29 April 2022, or (iii) vehicles that needs to transit through Norway to return to Russia.

Series of other economic measures and extension of existing sanctions

New restrictions are likewise adopted, and sanctions are extended in several areas to close loopholes.

New prohibition concerning the finance sector

Prohibition regarding public procurement

Export and import bans

In addition, appendix IX, concerning goods and technology that may contribute to increasing Russia's military and technological capabilities – and which are subject to a general export ban - has been expanded with the category "miscellaneous items" which amongst other now includes equipment for oil production or oil exploration, manufacturing equipment and machine tools.

Schjødt is ready to assist

Please note that these updates do not provide an exhaustive description of all sanctions in place, and the Ministry of Foreign Affairs my grant exemptions under certain circumstances. Any person or entity involved in business activities in any way related to Russia, Belarus or Ukraine should carefully assess how they are affected by the sanctions. Schjødt is ready to assist in this regard. Our sanctions team offers guidance on the increasingly complex and frequently changing sanctions regulations, including how to ensure compliance with the same.

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