RegRally Insights: Sanctions Essentials

ECOVIS ProventusLaw welcomes to our monthly newsletter on Sanctions, dedicated to everyone who wants to understand the latest trends and developments, get tips from our experts, and deepen their knowledge.

EU Adopts 15th Package of Restrictive Measures Against Russia

On December 16, the EU Council adopted its 15th package of restrictive measures aimed at curbing Russia’s ability to wage its unlawful war of aggression against Ukraine. The sanctions target military, industrial, and economic operations while addressing the circumvention of previous EU measures.

Key Elements of International Sanctions

1. New Listings:

84 Designations: Targeting 54 individuals and 30 entities.
Key targets include:

– Military units responsible for attacks on Ukrainian civilians.

– Russian energy sector managers.

– Individuals linked to child deportations and propaganda efforts.

– Non-EU actors, including Chinese entities and senior North Korean officials, supporting Russia militarily.

2. Maritime Measures:

Expansion of port access bans and service restrictions targeting Putin’s shadow fleet.
52 Additional Vessels: Designated to circumvent oil price caps, support Russia’s energy sector, transport stolen Ukrainian grain, or move military equipment.
Total designated vessels: 79.

EU Imposes First Sanctions for Destabilizing Activities

On December 16, 2024, the EU Council imposed restrictive measures for the first time against 16 individuals and three entities linked to Russia’s destabilising actions abroad. These measures target activities undermining EU member states, international organisations, and third countries.

Key Sanctioned Entities and Individuals

GRU Unit 29155: Responsible for foreign assassinations, bombings, and cyber-attacks in Europe.
African Influence Networks:

– Groupe Panafricain pour le Commerce et l’Investissement and its founder Harouna Douamba, engaged in pro-Russian covert influence campaigns.

– African Initiative news agency and editor-in-chief Artem Kureev, spreading disinformation.

– GRU official overseeing Wagner Group operations in Africa post-Prigozhin.

Doppelganger Campaign Leaders:

– Sofia Zakharova and Nikolai Tupikin, linked to Russian government propaganda campaigns.

Espionage and Influence Operations:

– Vladimir Sergiyenko was involved in intelligence against Germany.

– Visa Mizaev and his wife are key players in Russian espionage targeting German intelligence.

Sanction Mechanisms

Asset freezes and travel bans for listed individuals and entities.
Prohibition on providing funds or economic resources to sanctioned parties.

EU Expands Sanctions on Belarus

On December 16, 2024, the EU imposed sanctions on 26 additional individuals and two entities in Belarus. The listed include judges responsible for politically motivated sentences, officials overseeing correctional institutions where political prisoners face inhumane treatment, and others tied to repression of civil society and opposition. This expands the EU’s Belarus sanctions list to 287 individuals and 39 entities.

Baltic States Sanction Sakartvelo Officials for Protest Crackdowns

Lithuania, Latvia, and Estonia imposed national sanctions on 11 high-ranking officials from Sakartvelo (Georgia) accused of leading brutal crackdowns on peaceful protests, violating human rights, and undermining the rule of law. Lithuania banned the officials, including ruling party founder Bidzina Ivanishvili and Interior Minister Vakhtang Gomelauris, from entering the country for five years. This action reaffirms the Baltic States’ commitment to democratic values and solidarity with Sakartvelo’s civil society.

U.S. Sanctions Georgian Officials Under Global Magnitsky Act

The U.S. Treasury’s Office of Foreign Assets Control (OFAC) has sanctioned Georgian officials Vakhtang Gomelauri and Mirza Kezevadze for overseeing violent crackdowns on protests and abuses against journalists, activists, and opposition figures in 2024. Under Executive Order 13818 (Global Magnitsky), the designations align with similar UK actions, reflecting international efforts to address human rights violations in Georgia.

Treasury Sanctions Former Uzbek Officials for Human Rights Abuses

On the International Day for the Abolition of Slavery, the U.S. Treasury’s OFAC sanctioned three former Uzbek government officials under Executive Order 13818 for their roles in human trafficking and gender-based violence, including abuse of children in a state-run orphanage in Urgench. The State Department also imposed visa restrictions on the individuals and their families, reinforcing the U.S. commitment to combating gender-based violence and trafficking.