Update on sanctions developments in connection with the invasion of Ukraine


Flag of Ukraine in the dark.
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

  • The EU's fifth package includes both new types of financial sanctions and tightening of existing sanctions. The new prohibitions concerning the finance sector include prohibition on:

    • Selling, exporting etc. banknotes in Norwegian kroner or the official currency of an EU Member State to Russia or to a natural/legal person in Russia

    • Selling transferable securities issued after 3 May 2022, in Norwegian kroner or the official currency of an EU Member State

    • Receiving certain deposits and provision of services for cryptocurrencies such as providing crypto-asset wallet, accounts, or custody services to a Russian natural/legal person provided that the total value exceeds EUR 10 000

    • Providing support to certain legal entities established in Russia and which have a least 50 % public ownership or public control

    • Registering or making office spaces (incl. business address) available and providing administration services, as well as management services, to Russian trusts and similar structures. The regulation also prohibits persons from acting as a trustee, nominee shareholder, director, secretary or a similar position for a Russian trust or any similar legal arrangement as of 31 May 2022. Certain exemptions apply, and wind-down activities are permitted until 31 May 2022 for arrangements concluded before 30 April 2022.

Prohibition regarding public procurement

  • A general ban on participation of Russian companies in Norwegian public procurement The ban does not concern contracts entered before 30 April 2022 and which are performed by October 2022

Export and import bans

  • Further export and import bans are introduced, including prohibition on:

    • Export of goods and technology adapted for the use in oil refinery and converting it to liquified natural gas (gas liquefaction)

    • Export of goods and technology adapted for use in aviation or aerospace industry

    • Import of goods that generate significant revenues for Russia to Norway if they originate in Russia (incl. caviar, wood, cement, concrete, artificial stone)

    • Import of coal and other solid fossil fuels (briquettes, ovoids and similar solid fuels manufactured from coal, like coal gas, water gas, producer gas and similar gases) originated from Russia

    • Export of goods that may improve Russia's industrial capacity (incl. bulbs, chalk, hydrogen, nitrogen, methacrylic acid, articles of asphalt or of similar materials, types of machinery)

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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