News 23 Feb, 2022 Russia - new sanctions imposed in response to Ukraine crisis Tony Paulson Head of Asia & Corporate Director In reaction to reports of Russian armed forces moving into the Donetsk and Luhansk regions of Ukraine, there has been widespread and coordinated international action to impose sanctions on Russia.  Download PDF Details are set out below but Members should be aware that this a rapidly developing situation and individual States’ sanctions regimes may be subject to change (and potentially significant change) at short notice. The latest sanctions are largely confined to a limited number of entities and to trade to and from the disputed regions. It is clear however that should Russia incur further into Ukraine then much wider and far more punitive sanctions will be imposed, again potentially at short notice and with little or no wind-down periods. Members undertaking any trade with Russia are therefore strongly advised to bear these risks in mind even if they currently do not involve sanctionable activity or trade with the disputed regions.   United States President Biden issued a new Executive Order (EO) on 21 February 2022. A copy be found here . Although at an early stage and their evaluation is continuing, the Club’s U.S. attorneys Freehill Hogan and Mahar have issued a helpful Client Alert on the EO’s expected impacts – please see here . In brief, U.S. persons are prohibited from engaging in a variety of activities connected with the disputed regions (Section 1). Other sections may be construed as applying more widely to non-U.S. persons and to prohibit the provision of, broadly speaking, material support to designated entities. Importantly, it might also be read to prohibit calls at the port of Mariupol. There are however exemptions for the carriage of “agricultural commodities, medicine and medical devices and transactions related to the COVID-19 pandemic” to the disputed regions and general licences have also been issued