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RUSSIA’S WAR AGAINST UKRAINE:
SANCTIONS’ DIMENSION
IRYNA BOGDANOVA
JUNE 14, 2022
CLASSIFICATION OF IMPOSED SANCTIONS
Sanctions
of private
companies
SWIFT
sanctions
Sanctions
against
russian
sovereign
debt
Sanctions
against
the Central
Bank
Sanctions
against
3nancial
system
Withdrawal
of the MFN
treatment
Energy
sanctions
Transport
sanctions
Personal/individual
sanctions:
Political “elites”
Oligarchs
Propagandists
Technology
sanctions
+ Sport and Cultural
Sanctions
SANCTIONS OF PRIVATE COMPANIES
RUSSIAN COUNTER-SANCTIONS
•RUSSIA IMPOSES A BAN ON FOREIGN AIRCRAFT FLIGHTS FROM 36 STATES
•RESTRICTIONS TARGETING NATIONALS OF “UNFRIENDLY STATES” (AS OF NOW 48
SUCH STATES) Transaction with foreigners, e.g. entailing the ownership to
securities and real estate, can be carried out only upon
obtaining permits
No royalty payments to owners of patents from “unfriendly
countries” (allowing use without consent and without paying
any compensation)
Russia introduces ruble-based payment procedure for IP
related contracts
Restrictions on distribution of pro3ts by LLCs, partnerships
and production cooperatives to shareholders from unfriendly
states
STRATEGIES FOR CIRCUMVENTING ECONOMIC SANCTIONS
.
(ANTICIPATORY ACTIONS; ADAPTATION; EVASION OF SANCTIONS)
EXAMPLES OF EVASION
•PARALLEL IMPORT
ON MAY 6, 2022, THE RUSSIAN MINISTRY OF INDUSTRY AND TRADE HAS SET
THE LIST OF PRODUCTS AND PRODUCT CATEGORIES FOR WHICH PARALLEL
IMPORTS ARE ALLOWED
•RE-REGISTRATION OF LEASED AIRCRAFTS
AROUND 800 LEASED AIRCRAFTS WERE RE-REGISTERED IN RUSSIA
FURTHER POSSIBLE IMPROVEMENTS OF SANCTIONS
Criminalization of non-compliance and heavy
3nancial penalties for non-compliance
Enactment of secondary sanctions
Monitoring of compliance by civil society/media
(reputational costs for companies/governments
evading sanctions)
INTERESTING QUESTIONS TO PONDER ABOUT
Funds of
Central
bank
•There is a
precedent (Iran)
Funds of
oligarchs
•Proposal tabled
by Canada
Possibility to use
frozen funds to
rebuild Ukraine
THANK YOU!