News & Views

Update dated 25 February 2015: EU is prepared to impose more sanctions if the violation of the ceasefire agreement continues

25 February 2015

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On 18 February, High Representative / Vice-President Federica Mogherini gave a statement on violation of the ceasefire in Debaltseve. According to the statement “the EU stands ready to take appropriate action in case the fighting and other negative developments in violation of the Minsk agreements continue”.

Since March 2014 the EU Council has imposed different types of restrictive measures against the Russian Federation over the situation in Ukraine.

The most recent ones were imposed on 16 February 2015 by the Council Implementing Regulation 2015/240 of 9 February 2015 amending Regulation (EU) No 269/2014 of 17 March 2014 (as amended) designing a further 19 individuals (State Duma deputies, high-level Russian military authorities and persons related to military actions and the separatist Donetsk and Luhansk People’s Republics) and 9 new entities (separatist groups and one public movement) to the list of persons subject to asset freezes and travel bans. Previous additions to the list were published on 29 November 2014, when Ukrainian separatists, 13 individuals and 5 organisations, involved in the disputed elections in eastern Ukraine were added to the list. Currently the total number of individuals on the list is 151, with legal persons numbering 37. (Section 2 of our combined list)

Last week’s additions followed the latest actions by the EU Council, which on its meeting on 29 January 2015 agreed to add new names to the sanctions list and extend the validity of Regulation 269/2014 until September 2015.

On 29 January also the designation criteria for the freezing of funds targeting persons listed in Annex I of Council Regulation (EU) 208/2014 of 5 March 2014 (as amended) was clarified by Council Regulation (EU) 2015/138 of 29 January 2015. (Please see Section 1 of our combined list)

On 5 December 2014, the EU published Council Regulation (EU) No 1290/2014 of 4 December 2014 providing further clarifications to the sectoral (economic) sanctions specified in the Council Regulation (EU) No 833/2014 of 31 July 2014 (as amended). The amendments clarified, for example, the previously slightly unclear provisions on restrictive measures regarding oil exploration and production projects and the scope of restrictions on new loans and credits. In addition the EU Commission has given on 16 December the Guidance note on the implementation of certain provisions of Regulation (EU) No 833/2014.

On 19 December 2014 the Council imposed significant additional sanctions on investment, services and trade with Crimea and Sevastopol by Council Regulation (EU) No 1351/2014 of 18 December 2014 amending Regulation (EU) No 692/2014 concerning restrictive measures in response to the illegal annexation of Crimea and Sevastopol and on 4 December 2014. By these changes the previously imposed restrictive measures targeted for certain sectors were significantly expanded to include, for example, prohibitions to acquire, invest into or finance any entity in Crimea and Sevastopol and a new ban on services related to tourism activities were imposed.

Canada has imposed last week new economic sanctions and travel bans and both US and EU have warned Russia over violation of Minsk treaty. Additional restrictive measures could be expected in case the ceasefire will not hold in Ukraine. During the weekend US and UK have discussed new sanctions, so the coming weeks might bring new restrictions against Russia.

Main contacts


Victoria Goldman
Managing Partner Russia
Tel. +7 812 363 3377, +7 495 662 6434
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Luke Wochensky
Deputy Head, Moscow Office
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Anu Mattila
Specialist Partner
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Rabbe Sittnikow
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Jari Tukiainen
Specialist Partner, Head of Financial Regulation
Tel. +358 9 2288 4215 | Mobile +358 40 5181275