In conjunction with EU Member States’ diplomatic efforts on the Ukraine crisis, the European Union decided to target both Russian and Ukrainian individuals and entities considered responsible for actions undermining or threatening Ukraine’s territorial sovereignty.
On February 9, 2015, the EU published Council Implementing Regulation (EU) 2015/240 to expand the list of individuals and entities targeted under Regulation (EU) 269/2014 (see our earlier Sanctions Update of March 25, 2014). With effect from February 16, 2015, the EU imposed asset-freezing measures on 19 individuals – among which are some high-ranking Russian officials – and nine entities.
The following additional individuals and entities are now subject to restrictive measures:
Pavel Dremov (aka Batya)
Alexey Milchakov (aka Fritz, Serbian)
Arseny Pavlov (aka Motorola)
Mikhail Tolstykh (aka Givi)
Anatoly Ivanovich Antonov
Arkady Viktorovich Bakhin
Andrei Valeryevich Kartapolov
Iosif (Joseph) Davydovich Kobzon
Valery Fedorovich Rashkin
Cossack National Guard
Public Movement "Novorossiya"
From a practical perspective, the updated legislation does not significantly increase the burden of compliance procedures that companies must follow. Companies must, however, maintain robust screening procedures and ban virtually all transactions with targeted individuals and entities.