... involved in the energy sector and their partners in third countries. In the latter case, this also includes secondary financial sanctions. A specific feature of the nineteenth and eighteenth packages is the escalation of secondary sanctions related to Russia.
The concept of secondary sanctions is not defined in EU legislation. It is used more as a political concept. However, in a narrow sense, it can be understood as the use of blocking financial sanctions and other restrictive measures against those in third countries who ...
... geography of such investigations has also expanded significantly. Pinpoint criminal proceedings in Germany and the Netherlands until 2022 gave way to a broad practice of monitoring compliance with sanctions in almost all EU member states.
Ivan Timofeev:
Secondary Sanctions Against Russia's Partners Abroad: From Definition to Facts
2. The lack of transparency in EU sanctions legislation creates additional risks for Russian and foreign entities when conducting business under the EU’s jurisdiction.
The presence of contradictory ...
... persons from third countries who interact with a country or persons already under sanctions, or participate in circumventing them. Accordingly, primary sanctions are those that are applied to persons in the jurisdiction of the target country, for example, Russia. Secondary sanctions are usually introduced in the form of blocking financial sanctions. They are applied against targeted individuals or legal entities. Blocking sanctions involve freezing the assets of these persons and prohibiting virtually all transactions ...
... military-industrial complex or for certain dual-use goods. In June 2024, the interpretation of the concept of the Russian military-industrial complex was expanded to banks that were previously subject to sanctions. That is, a foreign bank risks
facing secondary sanctions
if its counterparty is any sanctioned Russian bank. Similar restrictions
appeared
in the fourteenth package of EU sanctions.
Difficulties in completing transactions, for example, through Chinese banks, or an increase in the cost of such transactions were reported in 2024, but Russian authorities ...
... been taken. It is quite possible that Brussels is setting aside steps for the further escalation of sanctions.
The UK has extended blocking financial sanctions to a number of large Russian industrial companies. The country has also decided to introduce secondary sanctions against Russia’s partners from third countries, but unlike Brussels, it has applied the mechanism of blocking sanctions to them.
They include companies from Turkey, China, the UAE and Switzerland.
The lists of blocked persons have also been expanded or are ...
... entities. The introduction of a large new package of restrictions can hardly be called a new phenomenon. Over the past year and a half, they have become routine. However, the latest wave of sanctions is notable for its emphasis on certain sectors of the Russian economy, as well as the practice of applying secondary sanctions against companies in third countries involved in circumventing American restrictions.
Ivan Timofeev:
US Congress and Sanctions Against Russia
Blocking financial sanctions today can be considered a key tool of restrictive measures....
Such sanctions are unlikely to ensure the blockade of Russia desired by the Western initiators. This was not achieved even with respect to Iran, whose economy is smaller than Russia's
Another package of US sanctions has caused a stir in connection with restrictive measures against companies from Kyrgyzstan ...
... to many criminal cases is that the basis for the accusatory documents is the electronic correspondence of the participants in the transaction, as well as signals to the authorities from the manufacturing companies, which were contacted by the accused Russian citizens and their partners.
Along with criminal cases, the number of cases of secondary sanctions, that is, blocking financial sanctions for transactions in favour of previously blocked persons, is also growing. Since the beginning of 2023, the US Treasury has imposed such sanctions on people from China, India, Armenia, Kyrgyzstan,...
... export restrictions, and criminal and administrative prosecutions. In the first case, the US Treasury simply imposes blocking sanctions on individuals and entities that are suspected of circumventing sanctions. Such measures were widely used against Russian counterparties abroad under all large packages of US sanctions in 2023. Citizens and companies from India, China, the United Arab Emirates, Switzerland, Liechtenstein, Cyprus, Malta, etc. fell under secondary sanctions. In each such case, the Americans had no problems with the official authorities of these countries. By default, it is understood that these persons acted at their own peril and risk, and not on the order of the government in their ...
... themselves. Here, the special representative will have more scope and prospects for securing compliance. Unlike government structures, business is showing much more nervousness and caution. Business fears secondary sanctions. If earlier the EU opposed secondary sanctions, today it is ready to apply them against Russia—such a legal mechanism has already appeared in Council Regulation (EU) No 269/2014. In addition, the European Union is working to harmonise the legislation of the member states aimed at the administrative and criminal prosecution of those who ...
