
The February 2022 events became not just a political earthquake. They have led to a most serious transformation of the oil and gas market.
Sanctions against Russia in reality will affect every major exporter and importer of oil and natural gas. The Western nations seek to strike a blow to the Russian economy which is based on export incomes from hydrocarbons. Accordingly, the sanctions target their production and sales. Since Russia is a leading exporter of oil and gas, the effect of sanctions will be global in scale indeed.
The choice of the United Kingdom and EU for analysis is clear: it was Europe that was the main market for Russian hydrocarbons prior to the beginning of the special military operation. Accordingly, European sanctions are the most significant and painful to Russian corporations.
The report is based on the chronological principle as it demonstrates the tightening of the sanctions regime.
The report is a complete guide to the sanctions introduced by the EU and United Kingdom as of the beginning of July 2022 and having a direct or indirect effect on oil and gas. The report contains hyperlinks to official European documents.
Our analysis not only enables an understanding of the logic behind the sanctioning actions of the United Kingdom and EU. It contains an evaluation of the enforcement practice showing how the sanctions have begun to be implemented. The report describes how European regulators themselves interpret the imposed sanctions and what possible responsibility their violation entails. The work also presents the initial reaction of Russian oil and gas companies to the moves of the European regulators.
Detailed description of sanctions enables exploring all their levels and possible implications. The report studies:
Attempts to close Western markets to Russian oil and gas companies
- Direct bans on buying and consuming Russian hydrocarbons
Restrictions on access for Russian corporations to trade infrastructure
- Including insurance and reinsurance of supplies, financial transactions, lending, export guarantees, services of traders and carrier
Technological sanctions that must become a barrier to Western equipment on its way to Russia
Personal sanctions against top managers and owners of oil and gas companies
Contents of the report:
INTRODUCTION | 4 |
UNITED KINGDOM SANCTIONS | 6 |
References to Sanctions Documents and Lists | 6 |
28 February | 6 |
1 March Package | 6 |
7 March Amendments and Announcement | 9 |
10 March Update of Sanctioned Individuals List | 10 |
15 March Ban on Issuing Export Guarantees. Economic Crime Act | 11 |
24 March Update of Sanctioned Individuals and Entities List | 12 |
Implications of Sanctions against SovComflot. Risks of Sanctions against Insurance and Reinsurance of Ships with Russian Minerals | 13 |
6 April Announcement of New Sanctions | 17 |
13 April Update of Sanctioned Individuals List | 18 |
14 April Package | 18 |
21 April General Licences for Banks | 25 |
22 April General Licence for Sberbank CIB UK Subsidiary | 26 |
New Trade Restrictions of 9 May (Updated on 31 May) | 26 |
Penalties for Violating UK Sanctions Regime | 27 |
EU SANCTIONS | 28 |
Links to Sanctions Documents and Lists | 28 |
Jurisdictions and General Context | 28 |
First Package of EU Restrictive Measures of 23 February 2022 | 32 |
Second Package of EU Restrictive Measures of 25 February 2022 | 32 |
Third Package of EU Restrictive Measures of 28 February 2022 | 38 |
Part Two of Third Package of EU Restrictive Measures of 1 March 2022 | 40 |
Repowereu Plan Outline on Reducing Dependence on Russian Fossil Fuels of March 8 | 41 |
Asset Freeze, Shipment Restrictions of March 9 | 42 |
Intentions to Withdraw the Status of Most-Favored-Nation and Impose New Financial Restrictions as of March 11 | 44 |
Fourth Package of EU Restrictive Measures of 15 March 2022 | 44 |
Due Diligence Measures to Prevent Circumvention of Sanctions on Exports of Goods (As Of April 1) | 52 |
Fifth Package of EU Restrictive Measures of 8 April 2022 | 53 |
Sixth Package of EU Restrictive Measures of 3 June 2022 | 69 |
CONCLUSION | 81 |
Date of release: | October 2, 2022 |