On 12 May 2014, the EU expanded the underlying criteria of its sanctions regime against Russia and the Ukraine to provide for the possible listing of the following categories of persons:

  • natural persons (and natural or legal persons, entities or bodies associated with them) (i) responsible for actively supporting or implementing actions or policies which undermine the territorial integrity, sovereignty and independence of Ukraine or the stability or security in Ukraine or (ii) who obstruct the work of international organisations in Ukraine; and
  • legal persons, entities or bodies in Crimea or Sevastopol whose ownership has been transferred contrary to Ukrainian law, as well as legal persons, entities or bodies which have benefited from such a transfer.

These new criteria were issued pursuant to Council Regulation (EU) No. 476/2014 and Council Decision 2014/265/CFSP. Initially, the EU only designated two types of person (and their associates): (i) those responsible for undermining or threatening the territorial integrity, sovereignty and independence of Ukraine and (ii) those responsible for the misappropriation of Ukrainian state funds or for human rights violations in Ukraine.

Thirteen individuals and two entities have been designated under the new criteria. This expansion of the list of designated individuals brings the total number of individuals designated by the EU to 61; this is the first time the EU has sanctioned entities pursuant to its Russia/Ukraine sanctions.

The designated individuals are: (1) Vyacheslav Viktorovich Volodin; (2) Vladimir Shamanov; (3) Vladimir Nikolaevich Pligin; (4) Petr Grigorievich Jarosh; (5) Oleg Grigorievich Kozyura; (6) Viacheslav Ponomariov; (7) Igor Mykolaiovych Bezler; (8) Igor Kakidzyanov; (9) Oleg Tsariov; (10) Roman Lyagin; (11) Aleksandr Malykhin; (12) Natalia Vladimirovna Pokloskaya; and (13) Igor Sergeievich Shevchenko.

The designated entities, both based in the Crimea, are PJSC Chernomorneftegaz, a gas company, and Feodosia, an oil supplier; according to the EU, both were appropriated by the Government of Crimea. PJSC Chernomorneftegaz was already designated by the US on 11 April 2014 under Executive Order (“E.O.”) 13660, and by Canada on 12 April 2014 pursuant to the Special Economic Measures (Ukraine) Regulations.

The EU Council noted that: “preparatory work by the Commission and Member States is underway on possible targeted measures, as requested by the European Council in March, so that further steps can be taken should events require. The European Union will pay particular attention to all parties’ attitudes and behaviour towards the holding of free and fair Presidential elections when deciding about possible future measures”.

Council Regulation (EU) No. 476/2014 (PDF)

Council Decision 2014/265/CFSP (PDF)

Council Conclusions on Ukraine (PDF)