Update on the Sanctions development in connection with the invasion of Ukraine


Closeup of glass building
Last week, the EU imposed additional sanctions in response to Russia's invasion of Ukraine. These include e.g. cutting a number of Russian banks from the SWIFT system as of 12 March 2022, and additional sanctions targeting the Russian finance, media and aviation sectors. In addition, Russia reportedly responded with its own counter-measures. Below is a summary of last week's developments.

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. 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.


New prohibition regarding SWIFT services

  • It is prohibited as of 12 March 2022 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



It may be noted that other Russian banks, including Sberbank and GazpromBank are by now not included in the prohibition mentioned above.

Increased restrictions targeting the Russian Central 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

New prohibition regarding the Russian Direct Investment Fund

  • In addition to current restrictions, it is as of 2 March 2022 prohibited to invest, participate or otherwise contribute to future projects co-financed by the Russian Direct Investment Fund.

  • The competent authorities 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 2 March 2022 or ancillary contracts necessary for the execution of such contracts.

The Russian Direct Investment Fund is Russia´s sovereign wealth fund established to make equity, co-investments, primarily in Russia, alongside reputable international financial and strategic investors.

New prohibition regarding euro denominated banknotes

  • It is as of 2 March 2022 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


New broadcasting ban

  • It is as of 2 March 2022 prohibited for operators to broadcast or to enable, facilitate or otherwise contribute to broadcast, any content, including transmission or distribution by any means, by the following media entities:

  • RT- Russia Today English

  • RT- Russia Today UK

  • RT - Russia Today Germany

  • RT - Russia Today France

  • RT- Russia Today Spanish

  • Sputnik


New prohibition regarding aircraft operated by Russia

  • It is as of 28 February 2022 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 the Union, except for:

  • Emergency landing or an emergency overflight.

  • When authorisation is given to an aircraft.


Several new persons have been added to the blocking/freezing sanctions listed, including:

  • Persons who are said to have facilitated the Russian military aggression from Belarus.

  • Russian oligarchs and businesspeople with connections to the Russian President, including e.g. the CEOs of Rosneft and Transneft.

  • Media people that are said to have spread anti-Ukrainian propaganda.

  • Members of the board of directors of the Russian Railways

  • Gas Industry Insurance Company SOGAZ

Russian counter-measures

Russia has reportedly adopted its own counter-measures to the sanctions. These include e.g.:

  • Prohibiting Russian residents (including e.g. Russia-registered companies) from transferring foreign currency:

    • to non-residents under loan agreements; and

    • to their accounts (deposits) opened with banks and other financial market organizations located outside the territory or the Russian Federation, as well as making money transfers without opening a bank account using electronic means of payment provided by foreign payment service providers.

  • Imposing a mandatory requirement for Russian residents participating in foreign economic activity, to sell 80% of the foreign currency proceeds received from any non-resident pursuant to foreign business activities since 1 January 2022, by exchanging such foreign currency proceeds into Rubels.

More sanctions ahead?

According to media reports, the USA and EU states are discussing the possibilities of introducing an import ban on Russian oil.

Furthermore, while Norway has expressed that it will follow suit with the EU sanctions, we are still waiting for Norway to formally adopt new sanctions.

Do you have any questions?