NATO and EU allies continue to make additions to the designated entities lists so all the members can ensure that they carry out careful examination and inspections using the updated lists.
Russia
The US Government has banned the import into the US of Russian crude oil, petroleum, petroleum fuels, oils and products, liquefied natural gas, coal and coal products, as set out in the Executive Order.
US law firm, Freehill Hogan & Mahar have issued a client alert clarifying that the import ban applies only to cargoes of Russian Federation origin, not to cargoes routed through Russia.
The EU has also prohibited the sale, supply, transfer or export, directly or indirectly of maritime navigation goods and technology to Russia, for use in Russia or for placing on board Russian flagged vessels, as well as providing related technical, broking or financial assistance, and maintenance, manufacture of such goods and technology.
The UK has announced on 8 March that it will phase out imports of Russian oil by the end of 2022.
Belarus
On 2 March, the EU expanded sanctions against Belarus, largely in line with those imposed against Russia. In particular, this includes:
- Export controls prohibit the sale, supply, transfer or export, directly or indirectly, of the following, whether or not originating in the EU, to any person/entity in Belarus or for use in Belarus of:
– All dual-use goods and technology listed in Annex I to Regulation (EU) 2021/821;
– goods and technology which might contribute to the military and enhancement of Belarus, or to the development of its defence and security sector; and
– various types of machinery. - The provision of certain related services, including brokering and financing/financial assistance is prohibited, including the provision of insurance/re-insurance in relation to certain machinery.
- There are new sanctions prohibiting the purchase, transport and import into the EU of the following if they originate in Belarus or have been exported from Belarus:
– Goods used for the production or manufacturing of tobacco products;
– mineral products;
– wood and charcoal products;
– cement and cement products;
– rubber products;
– iron and steel products; and
– potassium chloride (“potash”) products. - The provision of related services, including technical assistance, brokering services, financing/financial assistance and insurance/re-insurance is also prohibited.
US Belarus Sanctions
On 2 March, the US Department of the Treasury’s Office of Foreign Assets Control announced sanctions measures against Belarus.
The measures include extending the export controls recently imposed on Russia to Belarus:
- Introduces Commerce Control List (CCL)-based licence requirements for Belarus
- adds Belarus to 2 new Foreign Direct Product (FDP) rules, which imposes a “near total” ban on exports of items to both Russian and Belarusian military end users;
- imposes a licence review policy of denial applicable sensitive items that support Belarus’s defence, aerospace, and maritime industries;
- restricts the use of EAR licence exceptions;
- expands the existing military end use/user control to include Belarus for all items subject to the EAR, other than certain food and medicine; and
- adds JSC Integral and the Ministry of Defence of the Republic of Belarus to the Entity List as military end users.
At the same time, it is important to recall that the economic sanctions targeting Russia continue to evolve and escalate with many being coordinated among the EU, UK, US, and their allies including sanctions against President Putin and the Central Bank of Russia. Standard Club’s experts Mrs Ursula O’Donnell and Mrs Gina Venezia provide a summary of some of the recent actions.
On 5 March 2022, the Singapore government imposed sanctions against Russia in response to the ongoing conflict in Ukraine.
Also, International Association of Classification Societies (IACS) voted to expel the Russian Maritime Register of Shipping from their ranks.
