EU Sanctions on Russia Related to the Ukraine Conflict

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Updated February 13, 2018
EU Sanctions on Russia Related to the Ukraine Conflict
The European Union (EU), like the United States, has
Restrictions on trade, investment, and tourism
imposed sanctions against Russia for its annexation of
services with the occupied Crimea region. These
Ukraine’s Crimea region in 2014 and its subsequent support
measures are currently in force through June 23, 2018
of separatists in eastern Ukraine. Many Members of
(Council Decision 2014/386/CFSP, June 23, 2014).
Congress have welcomed EU efforts to resolve the crisis in
Ukraine and have broadly supported U.S.-EU coordination
Also, as of February 2018, the EU has frozen assets of and
on sanctions. The Countering Russian Influence in Europe
imposed visa bans on 15 former Ukrainian officials (serving
and Eurasia Act of 2017 (P.L. 115-44; Countering
in the previous government of Viktor Yanukovych) for the
America’s Adversaries Through Sanctions Act [CAATSA],
misappropriation of Ukrainian state funds. These measures
Title II; 22 U.S.C. 9501 et seq.) expanded the potential for
are currently in force through March 6, 2018 (Council
U.S. sanctions on Russia, raising concerns among EU
Decision 2014/119/CFSP, March 5, 2014).
members. Congress included language in the act to reassure
the EU that the United States would seek the EU’s input
EU and U.S. Sanctions Compared
before imposing new sanctions that could affect EU gas
In the first half of 2014, U.S. and EU sanctions focused
imports from Russia or European entities that finance or
mostly on denying visas to and imposing asset freezes on
support the construction of Russian export pipelines. Some
Russian and Ukrainian government officials and pro-
EU qualms persist about the possible impact of U.S.
Russian separatists. Given the EU’s extensive economic ties
sanctions on the EU and their implications for U.S.-EU
with Russia, many in the EU were hesitant to escalate
cooperation on Ukraine. (Also see CRS In Focus IF10694,
sanctions. Amid congressional pressure, the Obama
Countering America’s Adversaries Through Sanctions Act.)
Administration announced sectoral sanctions on selected
Russian financial, defense, and energy companies on July
EU Sanctions
16, 2014. The next day, Malaysia Airlines Flight MH17
Imposing EU sanctions—or restrictive measures in EU
was shot down over eastern Ukraine (with 298 people
parlance—requires the unanimous agreement of all 28 EU
aboard, two-thirds of whom were Dutch citizens).
member states. Most EU sanctions are imposed for a
Intelligence sources indicated that the plane was brought
defined period of time, usually six months or a year, after
down by separatist forces using a missile supplied by the
which they require renewal to remain in place. Unanimity
Russian military. This event prompted the EU to expand its
among EU member states is required to extend EU
sanctions list and impose new sectoral sanctions on Russia.
sanctions. In response to Russia’s annexation of Crimea and
its actions against the territorial integrity of Ukraine, the EU
Asset Freezes and Travel Bans
has imposed three sets of sanctions against Russia:
As of February 2018, the United States has designated 181
individuals and 140 entities. The U.S. and EU lists of
Restrictive measures on individuals and entities in
designated individuals and entities, however, are not
Russia and Ukraine believed to be involved in the
exactly the same, with various legal and political reasons
annexation of Crimea and destabilization of eastern
accounting for some of the differences. The EU has
Ukraine. Designees are subject to asset freezes and, for
imposed sanctions on more individuals and entities directly
individuals, visa bans. As of February 2018, the EU has
related to the fighting in Ukraine: military officials,
designated 150 individuals and 38 entities. These
insurgents, and battalions. The United States has
measures are currently in force through March 15, 2018
specifically designated more entities affiliated with already-
(Council Decision 2014/145/CFSP, March 17, 2014).
designated individuals and entities, as well as more
companies operating in Crimea, whereas the EU has
Economic sanctions targeting Russia’s finance,
blanket restrictions on Crimea-related activities. The EU is
defense, and energy sectors (sectoral sanctions). The
unable to impose restrictive measures on some individuals
EU requires its member states to impose lending and
because those individuals hold dual citizenship with EU
investment restrictions on five major state-controlled
countries. Finally, the EU removes individuals due to death
Russian banks, three defense firms, and three energy
(the United States requires a decedent’s survivors to
companies, as well as their subsidiaries outside the EU.
petition for removal).
The sanctions also ban the import and export of arms;
the sale of dual-use goods and technology to Russian
Sectoral Sanctions
military end users and nine mixed companies; and sales
EU and U.S. restrictions against lending and/or investments
of equipment, technology, and services for certain oil-
with entities in specific sectors mostly overlap and target a
development projects (deepwater, Arctic offshore, and
handful of key companies in the financial, defense, and
shale). These measures are currently in force through
energy sectors, as well as exports and services related to
July 31, 2018 (Council Decision 2014/512/CFSP, July
deepwater, Arctic offshore, or shale oil projects in Russia
31, 2014).
(see Table 1). The manners in which the United States and
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EU Sanctions on Russia Related to the Ukraine Conflict
the EU employ this measure differ somewhat but appear to
that new U.S. sanctions on pipeline ventures would not be
accomplish largely the same outcome. At present, the
imposed without coordinating with U.S. allies (§232).
United States specifically identifies 290 entities (with
subsidiaries accounting for most of that total) that are
Some in Europe remain wary that implementation of new
subject to sectoral sanctions. Although the EU has not
U.S. sanctions could affect European energy projects.
explicitly identified subsidiaries of sanctioned entities, it
Perhaps most notable are German and Austrian concerns
has restricted lending and investment with majority-owned
about possible effects on the proposed Nord Stream 2
subsidiaries outside the EU.
pipeline (for transporting gas from Russia to Germany, via
the Baltic Sea). Despite internal EU divisions on Nord
Additionally, CAATSA expanded potential targets for U.S.
Stream 2, the European Commission nonetheless made the
sectoral sanctions. The act amended the Ukraine Freedom
general assertion that it reserves the right to take
Support Act of 2014 (P.L. 113-272; 22 U.S.C. 8921 et seq.)
“appropriate steps,” if necessary, to protect EU interests.
to require sanctions on foreign persons that make “a
The Commission also continues to express concern that
significant investment” in deepwater, Arctic offshore, or
new U.S. sanctions could affect EU efforts to diversify its
shale oil projects in Russia. CAATSA also expanded U.S.
energy sector. In addition, some Europeans are anxious that
sanctions to apply to U.S. persons engaged in such projects
codifying U.S. sanctions may reduce flexibility in their
worldwide when identified entities have an ownership
negotiations with Moscow on the Ukraine conflict.
interest of at least 33% (or a majority of voting interests).
Finally, CAATSA authorizes sanctions on U.S. or foreign
Table 1. EU and U.S. Sectoral Sanctions
entities that engage in trade or make investments of a
certain value that enhance Russia’s ability to construct
EU
United States
energy export pipelines.
Financial Sector
U.S. and EU policies are comparable in restricting most
Gazprombank
Gazprombank (+ affiliated)
arms trade with and dual-use exports to Russia, but EU
Rosselkhozbank
Rosselkhozbank (+ affiliated)
arms-trade sanctions were applied to future contracts only.
Sberbank
Sberbank (+ affiliated)
The EU and the United States also addressed the issue of
existing sales and service contracts on energy development
VEB
VEB (+ affiliated)
projects differently. The EU allowed for the continuation of
VTB Bank
VTB Bank (+ affiliated)
existing contracts and agreements, in certain cases with
Defense Sector
authorization at the national level. The United States
generally prohibited, other than a brief wind-down period,
Oboronprom (Rostec
Rostec (+ affiliated)
the continuation of existing contracts and agreements unless
subsidiary)

otherwise authorized by the Department of the Treasury’s
United Aircraft Corporation
Office of Foreign Assets Control.
Uralvagonzavod
Current Status of EU Sanctions and U.S.-
EU Cooperation
Energy Sector
The EU has tied lifting sanctions to the full implementation
Gazpromneft
Gazpromneft
of the Minsk peace agreements for Ukraine, and the EU
Rosneft
Rosneft (+ affiliated)
appears committed to maintaining sanctions on Russia. At
Transneft
Transneft
the same time, questions persist in some EU countries about
Novatek (+ affiliated)
the effectiveness of the sanctions, especially amid concerns
that they could be hindering EU relations with Russia on
Energy Development Projects
other global priorities and harming European business
interests. Some European officials have periodically floated
Companies are not specified.
Gazprom (+ affiliated)
ideas about restructuring the sanctions. Others firmly reject
Gazpromneft
suggestions to relax or recalibrate EU sanctions and have
Lukoil
urged the Trump Administration to uphold U.S. sanctions.
Rosneft (+ affiliated)
Although many in the EU welcomed congressional efforts
Surgutneftegaz (+ affiliated)
in 2017 to ensure that U.S. sanctions on Russia were
Note: The EU and the United States have imposed additional
maintained, certain initially proposed provisions in
sanctions on several other defense firms. Also see CRS In Focus
CAATSA generated unease. Some Europeans objected to
IF10552, U.S. Sanctions on Russia Related to the Ukraine Conflict.
what they viewed as a unilateral imposition of sanctions;
they worried this could complicate the carefully crafted
political consensus on the EU’s own sanctions
Kristin Archick, Specialist in European Affairs
and weaken
U.S.-EU cooperation on Ukraine. EU concerns were
Dianne E. Rennack, Specialist in Foreign Policy
appeased to some degree by language inserted in the act
Legislation
stating that the President should “continue to uphold and
Cory Welt, Analyst in European Affairs
seek unity” with European partners on sanctions (§212) and
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EU Sanctions on Russia Related to the Ukraine Conflict



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