UK Designates 89 Individuals and Three Entities: On September 26, 2022, in response to Russia’s “sham” referendums to annex four Russian-occupied regions in Ukraine, the UK designated an additional 92 individuals and entities. “Today’s sanctions will target those behind these sham votes, as well as the individuals that continue to prop up the Russian regime’s war of aggression,” said the UK’s Foreign Secretary, James Cleverly. The new tranche of sanctions included IMA Consulting, an agency that reportedly has a contract to manage the public campaigns for the referendums, and Goznak, a company that produces state documents, including expedited passports in the Russian-controlled regions of Ukraine. The sanctioned individuals included four oligarchs (God Nisanov, Zarakh Illiev, Iaksander Makhmudov, and Igor Makarov), 49 board members from Gazprombank, Sberbank, and Sovcombank, and 33 officials and collaborators located in the occupied regions of Ukraine, among others.

U.S. Adds Another Iranian Cargo Plane to List of Export Controls Violators: On September 26, 2022, the U.S. Bureau of Industry and Security (“BIS”) added another Iranian-owned and -operated aircraft to the list of aircraft that have apparently violated U.S. export controls. An airplane owned by Saha Airlines, which itself is owned and operated by the Islamic Republic of Iran Air Force, flew into Russia without the proper authorization. There are now 184 aircraft that have appeared to violate U.S. export controls.

U.S. Files Criminal Charges Against Russian Oligarch: On September 29, 2022, the U.S. Department of Justice (“DOJ”) filed criminal charges against Russian oligarch Oleg Vladimirovich Deripaska and his associates, for conspiring to evade U.S. sanctions. The DOJ alleges that Deripaska, a U.S.-sanctioned person, relied on holding companies and intermediaries to conduct transactions in the United States, including maintaining real estate, and to attempt to expatriate over $3 million in the United States to a bank account in Russia belonging to a Deripaska-controlled entity, all in violation of U.S. sanctions.

U.S. and Europe Prepare Additional Sanctions: The U.S. and EU are reportedly in close coordination in preparing a new round of sanctions. “We are working on more sanctions. Our European colleagues have said they will continue,” said U.S. Ambassador James O’Brien, who leads the U.S. Department of State’s Office of Sanctions Coordination, during a Senate Foreign Relations Committee hearing on September 28, 2022. “We’ll keep coordinating. Everything is on the table.”

During the hearing, Ambassador O’Brien said that U.S. sanctions would target the finance, technology, human rights, and energy sectors of Russia. Both commercial and military technology would both be included. According to White House spokesperson Karine Jean-Pierre, individuals and entities that support Russia’s annexation will also be sanctioned. State Department spokesperson Ned Price told reporters that additional measures could be expected in the “coming days.”

On the same day, European Commission President Ursula von der Leyen introduced the EU’s eighth sanctions package. “We do not accept the sham referenda and any kind of annexation in Ukraine, and we are determined to make the Kremlin pay for this further escalation,” Ms. von der Leyen said at a press conference. The proposed sanctions package includes: (1) designations of additional individuals and entities; (2) an import ban on Russian products; (3) an extended list of products prohibited for export to Russia, to include additional aviation items, electronic components, and specific chemical substances; (4) additional bans on European services to Russia; (5) a prohibition for EU nationals to sit on governing bodies of Russian state-owned enterprises; (6) an price cap on Russian oil exported to third countries; and (7) the development of an EU list of individuals that evade the EU’s sanctions on Russia. Media reports indicate that EU officials hope the sanctions package will be approved in the next week.