On 21 February, Russia recognised the independence of two regions in Ukraine, the “Donetsk and Luhansk People’s Republics,” and in response, the United States, United Kingdom, and European Union announced additional sanctions measures.
Companies operating in these regions as well as any neighboring or potentially separatist areas in Ukraine should evaluate whether any transactions and business relationships are potentially implicated by the new sanctions including dealings with sanctioned persons, or entities owned or controlled by sanctioned persons, or whether activity in these regions may be targeted by applicable trade restrictions.
See our full alert here for further insights on first rounds of sanctions.
See our second alert here on the latest US sanctions.
On February 25th, the EU released its second round of measures including sanctions on President Putin: https://www.consilium.europa.eu/en/press/press-releases/2022/02/25/russia-s-military-aggression-against-ukraine-eu-imposes-sanctions-against-president-putin-and-foreign-minister-lavrov-and-adopts-wide-ranging-individual-and-economic-sanctions/
The UK also announced sanctions on President Putin on the 25th and released a general license to authorise wind down of transactions with VTB. Further sanctions are expected in line with prior announcements: https://www.gov.uk/government/news/foreign-secretary-imposes-uks-most-punishing-sanctions-to-inflict-maximum-and-lasting-pain-on-russia
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