Major Sanctions Developments

UK Adds Three Firms to Russian Sanctions List. The UK Foreign, Commonwealth and Development Office added three entities to its Russia-related sanctions list. Photon Pro LLP, Majory LLP, and Djeco Group LP are subject to asset freezes. The companies were designated under the Russian sanctions regime, which freezes funds and economic resources of certain persons, entities, or bodies involved in destabilizing Ukraine and threatening its territorial integrity and independence.

Lithuania Ends Russian Gas Imports. Lithuania became the first EU country to cut off Russian gas imports completely, with the two other Baltic states, Estonia and Latvia, also temporarily stopping its flow. The country will rely on liquefied natural gas from its terminal instead.

Sanctions Effects and Enforcement

Financial Analytics Firm S&P Global Settles Apparent Violations of Ukraine-Related Sanctions Regulations. The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) announced that New York-based financial analytics company S&P Global, Inc. has agreed to pay $78,750 to settle its potential civil liability for apparent violations of the Ukraine-Related Sanctions Regulations. The apparent violations occurred when S&P Global and its subsidiary Petroleum Industry Research Associates reissued and redated multiple invoices to continue to extend credit to JSC Rosneft, a state-owned Russian oil company that was placed on OFAC’s Sectoral Sanctions Identification List. The settlement amount reflects OFAC’s determination that S&P Global’s apparent violations were non-egregious and not voluntarily self-disclosed.

Sanctions Outlook

International Leaders Promise Consequences, Sanctions for Alleged War Crimes. There are increasing calls for further sanctions including a complete ban on Russian gas exports after images emerged of civilian dead strewn through the streets of Bucha, a city in the Kyiv region that had been recently occupied by the Russian military. UK Prime Minister Boris Johnson, German Vice-Chancellor Robert Habeck, and Ukrainian President Volodymyr Zelenskyy said the killings amounted to war crimes. French President Emmanuel Macron also referred to the actions in Bucha as a “crime.” The head of the European Council, Charles Michel, said he was shocked by “haunting images of atrocities committed by [the] Russian army,” adding that “further EU sanctions and support are on their way.”

German Minister Calls for Gas Ban Amid Growing Pressure. In a sign of a potential major shift in policy, Germany’s Defense Minister Christine Lambrecht said the European Union should consider an outright ban on Russian gas. That sentiment was shared by the leader of Italy’s junior coalition party. German Chancellor Olaf Scholz warned fresh sanctions would be imposed in the coming days, a promise French President Emmanuel Macron echoed. Macron suggested these would target Russia’s oil and coal industries but did not mention gas. British Prime Minister Boris Johnson also said his country would step up its sanctions and military support.

Ukrainian Foreign Minister Urges G7 Nations to Impose More Sanctions on Russia. Ukrainian Foreign Minister Dmytro Kuleba called on leaders of the Group of Seven nations to impose new sanctions on Russia after Ukraine accused Moscow of carrying out a “massacre” in the town of Bucha. Kuleba said the sanctions against Russia must include an embargo on oil, gas, and coal; the closure of all ports for Russian ships and goods; and the disconnection of all Russian banks from the SWIFT international messaging network. Mykhailo Podolyak, an adviser to the head of the President’s Office, also made a similar call from international partners.

President Maia Sandu Says Imposing Sanctions on Russia Exposes Moldova to “Multiple Vulnerabilities.” Moldovan President Maia Sandu said her government has not joined other nations in implementing sanctions against Russia because it would threaten Russian gas supplies to Moldova. Speaking before the press, Sandu said any trade restrictions her country can impose would not be felt by Russia anyway as the ongoing assault on Ukraine is already preventing Moldovan exports from entering the Russian market. Sandu said Moldova's western allies understood her government’s decision not to sanction Russia, stressing her country’s “multiple vulnerabilities” both in terms of security and economy. Almost 100,000 Ukrainians fleeing the warzones have sought refuge in Moldova.