On July 25th , the European Union added 15 individuals and 18 entities to the EU list of sanctions targets. The 15 new named individuals are a mix of Russian officials and Ukrainian separatists accused of supporting actions and policies which undermine the territorial integrity, sovereignty and independence of Ukraine. Nine of the entities were named for “undermining the territorial integrity, sovereignty and independence of Ukraine” and include the self-proclaimed Lugansk and Donetsk “People’s Republics” and other separatist militias and organizations. The other nine entities were named as “entities whose ownership has been transferred contrary to Ukrainian law,” all located in Crimea.

Accordingly, all funds and economic resources belonging to, or owned or controlled by, these individuals and entities are required to be frozen, and no funds or economic resources may be made available, directly or indirectly to or for their benefit. These obligations and prohibitions apply:

  • within the EU
  • to natural persons who are nationals of any EU member state, wherever such persons are located
  • to legal persons, entities or bodies, wherever located, that are incorporated or constituted in any EU member state
  • to any legal persons, entities or bodies in respect of their business done in whole or in part in the EU.

The newly sanctioned entities and individuals are as follows:

Entities:

ARMY OF THE SOUTHEAST

AZOV DISTILLERY PLANT (a.k.a. Crimean enterprise ‘Azov distillery plant’)

DONBASS PEOPLE'S MILITIA

DONETSK PEOPLE'S REPUBLIC

FEDERAL STATE OF NOVOROSSIYA

GREAT DON ARMY (a.k.a. International Union of Public Associations Great Don Army)

KERCH COMMERCIAL SEA PORT (a.k.a. State enterprise ‘Kerch commercial sea port’)

KERCH FERRY (a.k.a. State ferry enterprise ‘Kerch ferry’)

LUGANSK GUARD LUHANSK PEOPLE'S REPUBLIC (a.k.a. Lugansk People's Republic; a.k.a. People's Republic Of Luhansk)

MAGARACH (a.k.a. ‘State enterprise Magarach of the national institute of wine’)\

MASSANDRA (a.k.a. State concern ‘National Association of producers “Massandra”’)

NIZHNYAYA OREANDA (a.k.a. Resort ‘Nizhnyaya Oreanda’)

NOVY SVET (a.k.a. State enterprise ‘Factory of sparkling wine Novy Svet’)

SEVASTOPOL COMMERCIAL SEAPORT (a.k.a. State enterprise ‘Sevastopol commercial seaport’)

SOBOL

UNIVERSAL-AVIA (a.k.a. State enterprise Universal-Avia)

VOSTOK BATTALION

Individuals:

ANTYUFEYEV, Vladimir (aka Vladimir SHEVTSOV, Vladimir Iurievici ANTIUFEEV, Vladimir Gheorghievici ALEXANDROV, Vadim Gheorghievici SHEVTSOV)

BEREZIN, Fedir Dmytrovych

BESEDA, Sergey (a.k.a. BESEDA, Sergei; a.k.a. BESEDA, Sergei Orestovoch)

BORTNIKOV, Aleksandr Vasilievich

DEGTYAREV, Mikhail Vladimirovich

FRADKOV, Mikhail Efimovich

GRYZLOV, Boris Vyacheslavovich

GUBAREV, Pavel

GUBAREVA, Ekaterina

KADYROV , Ramzan Akhmadovitch

KAUROV, Valery Vladimirovich

NURGALIEV, Rashid Gumarovich

PATRUSHEV, Nikolai Platonovich

TKACHYOV, Alexander Nikolayevich

ZDRILIUK, Serhii Anatoliyovych

At the same time, the European Council issued a Decision expanding the grounds on which sanctions could be imposed to include “legal persons, entities or bodies supporting, materially or financially, actions which undermine or threaten the territorial integrity, sovereignty and independence of Ukraine; … or natural and legal persons, entities and bodies actively supporting, materially or financially, or benefiting from, Russian decision-makers responsible for the annexation of Crimea or the destabilisation of Eastern Ukraine”.

It is reportedly anticipated that individual “cronies” of President Putin will be added to the EU list shortly. Numerous reports have indicated that the EU is considering broader sectoral sanctions, and draft legislation is now under consideration. This draft legislation would bar Europeans from investing in new debt or equity issued by state-owned Russian banks (50% or more owned by the Russian government), which constitute most of the largest financial institutions in the country, effectively denying them access to the European capital markets. The United States Sectoral Sanctions Identification List has already targeted two Russian banks with this type of sanction. The draft legislation would also prevent the export of certain key energy technologies. An arms embargo and restrictions on exports of dual-use items for military use are also reportedly under consideration. The 28 member state ambassadors are continuing their meetings this week to discuss.

Despite reported disagreements among the EU member states as to the scope of proposed broader sanctions, as the situation in Ukraine appears to heat up, continued vigilance to changes in the sanctions regimes remains the order of the day.