On 20 February 2014, the EU announced its decision to introduce targeted sanctions against "those responsible for human rights violations, violence and use of excessive force” in Ukraine. The detailed measures will be announced shortly, but they are expected to include asset freezes and visa bans. In addition, EU Member States have agreed to suspend export licences on equipment which might be used for internal repression and reassess export licences for equipment covered by Common Position 2008/944/CFSP, i.e. military technology and equipment.
The UK’s Export Control Organisation (“the ECO”) is currently reviewing whether or not it is necessary to revoke, suspend or amend any relevant licences in light of these developments and will notify any affected exporters directly. The ECO has also warned that licence applications for exports to Ukraine are likely to take longer than normal.
Companies currently exporting, or considering exporting, to Ukraine should closely monitor the EU and its Member States’ sanctions as these may well be extended if the political situation in Ukraine worsens.