Following Russia's invasion of Ukraine in February 2022, the United States, the European Union,^[1] and other countries,^[2] introduced or significantly expanded sanctions to include Vladimir Putin and other government members,^[3] and cut off "selected Russian banks" from SWIFT,^[4] triggering the 2022 Russian financial crisis and massive international boycott of Russia and Belarus.

Background and history of sanctions and ramifications

History of sanctions

Western countries and others imposed limited sanctions on Russia when it recognised the independence of Donbas. With the commencement of attacks on 24 February, a large number of other countries began applying sanctions with the aim of crippling the Russian economy.^[5] The sanctions were wide-ranging, targeting individuals, banks, businesses, monetary exchanges, bank transfers, exports, and imports.^[6][7][8] The sanctions included cutting off major Russian banks from SWIFT, the global messaging network for international payments, although there would still be limited accessibility to ensure the continued ability to pay for gas shipments.^[9] Sanctions also included asset freezes on the Russian Central Bank, which holds $630 billion in foreign-exchange reserves,^[10] to prevent it from offsetting the impact of sanctions^[11][12][13] and implicated the Nord Stream 2 gas pipeline.^[14] By 1 March, the total amount of Russian assets being frozen by sanctions amounted to $1 trillion.^[15]

Major multinational companies, including Apple, IKEA, ExxonMobil, and General Motors, have decided themselves to apply sanctions to Russia, acting as international law enforcers on behalf of states.^[16][17] Ukrainian and Western governments have explicitly urged the global private sector to help uphold international law, and the EU, UK and Australia have also called on global digital platforms to remove pro-Russian propaganda.^[16] Multinational companies have disengaged from Russia to comply with sanctions and trade restrictions imposed by home states, but also on their own accord, beyond what was required by law, to avoid the economic and reputational risks associated with maintaining commercial ties with Russia.^[16][17]

Several countries that are historically neutral, such as Switzerland and Singapore,^[18][19] have agreed to sanctions.^[20][21] Some countries also applied sanctions to Belarusian organisations and individuals, such as President Alexander Lukashenko, because of Belarus' involvement in the invasion.^[22] Since 1969, Germany had maintained a policy called Ostpolitik, choosing dependence on Russian energy to maintain peaceful relations with Russia and to integrate it in to Europe, while allowing defence spending to fall.^[23]

In response to the invasion, Germany's new chancellor, Olaf Scholz, decided to suspend the Nord Stream 2 pipeline and announced a new policy of energy independence from Russia, admitting that Ostpolitik was a failure. In addition, Germany provided arms shipments to Ukraine, the first time that it provided arms to a country at war since the end of World War II. Germany also increased defence expenditures by approximately $100 billion, by some estimates making it the third largest military spender in the world.^[23] This change from a policy of appeasement to brinkmanship has been called a new epoch in German policy by The Economist.^[24]

Upon his arrival for the NATO extraordinary summit in Brussels on 24 March, Biden indicated that further economic sanctions would be placed against Russia, including restrictions on the Russian Central Bank's use of gold in transactions and a new round of sanctions that targeted defense companies, the head of Russia's largest bank, and more than 300 members of the Russian State Duma.^[25]

On 27 February, Putin responded to the sanctions, and to what he called "aggressive statements" by Western governments, by ordering the country's "deterrence forces"—generally understood to include its nuclear forces—to be put on a "special regime of combat duty". This novel term provoked some confusion as to what exactly was changing, but US officials declared it generally "escalatory".^[26] Following sanctions and criticisms of their relations with Russian business, a boycott movement began and many companies and organisations chose to exit Russian or Belarusian markets voluntarily.^[27] The boycotts impacted many consumer goods, entertainment, education, technology, and sporting organisations.^[28]

The US instituted export controls, a novel sanction focused on restricting Russian access to high-tech components, both hardware and software, made with any parts or intellectual property from the US. The sanction required that any person or company that wanted to sell technology, semiconductors, encryption software, lasers, or sensors to Russia request a licence, which by default was denied. The enforcement mechanism involved sanctions against the person or company, with the sanctions focused on the shipbuilding, aerospace, and defence industries.^[29] As an effect of the sanctions, Russian elites shifted funds worth hundreds of millions of dollars from sanctioning countries, like the UK and Switzerland, to countries that have not imposed sanctions, like the United Arab Emirates.^[30]

As a result of the economic sanctions imposed by the US and EU against Russia, the latter was reported in May 2022 of using its gold reserves to support the economy, despite a ban on trading gold as well. A Switzerland-based NGO, Swissaid, demanded transparency in the source of the gold imports from the United Arab Emirates following concerns about its potential origin being Russia. Since economic sanctions were imposed against Moscow after its invasion of Ukraine, Swiss gold refineries stopped importing any gold from the country. However, the recent increase in imports from UAE since Russian sanctions have raised concerns about Russia using UAE as a means to trade its gold with Switzerland-based refineries, thus, violating sanctions. Out of the many Swiss gold refineries, only Valcambi indicated importing gold from the UAE in March 2022, while others refused. Swissaid demanded stricter laws along with improved enforcement on gold origins. Some refineries in Switzerland don’t import gold from Dubai due to conflict with the verifiability of its origins.^[31]

Sanctions

Western countries and others began imposing limited sanctions on Russia when it recognised the independence of self-declared Donbass republics. With the commencement of attacks on 24 February, a large number of other countries began applying sanctions with the aim of crippling the Russian economy. The sanctions were wide-ranging, targeting individuals, banks, businesses, monetary exchanges, bank transfers, exports, and imports.^[1][2][32]

After Russia invaded Ukraine on 24 February 2022, two countries that had not previously taken part in sanctions, namely South Korea^[33] and non-UN member state Taiwan,^[34] engaged in sanctions against Russia. On 28 February 2022, Singapore announced that it will impose banking sanctions against Russia for Ukraine invasion, thus making them the first country in Southeast Asia to impose sanctions upon Russia.^[35]

The sanctions also included materials that could be used for weapons against Ukraine, as well as electronics, technology devices and other related equipment, which were listed in a detailed statement on 5 March.^[36][37]

On february 25 and 1 March 2022 Serbia, Mexico and Brazil have announced that they would not be participating in any economic sanctions against Russia.^{[38][39][40][41]}

On 28 February 2022, the Central Bank of Russia was blocked from accessing more than $400 billion in foreign-exchange reserves held abroad^[42][43] and the EU imposed sanctions on several Russian oligarchs and politicians.^[44] On the same day US Foreign Assets Control (OFAC) has prohibited United States persons from engaging in transactions with Central Bank of Russia, Russian Direct Investment Fund (including its predcessor, JSC RDIF, sanctioned previously), Limited Liability Company RVC Management Company, and Kirill Dmitriev, a Vladimir Putin's ally, personally.^[45][46][47]

Sergei Aleksashenko, the former Russian deputy finance minister, said: "This is a kind of financial nuclear bomb that is falling on Russia."^[48] On 1 March 2022, the French finance minister Bruno Le Maire said the total amount of Russian assets being frozen by sanctions amounted to $1 trillion.^[49]

Faisal Islam of BBC News stated that the measures were far from normal sanctions and were "better seen as a form of economic war". The intent of the sanctions was to push Russia into a deep recession with the likelihood of bank runs and hyperinflation. Islam noted that targeting a G20 central bank in this way had never been done before.^[50] Deputy Chairman of the Security Council of Russia and former president Dmitry Medvedev derided Western sanctions imposed on Russia, including personal sanctions, and commented that they were a sign of "political impotence" resulting from NATO's withdrawal from Afghanistan. He threatened to nationalise foreign assets that companies held inside Russia.^[51]

Fossil fuels and other commodities

On 8 March, President Joe Biden ordered a ban on imports of oil, gas and coal from Russia to the US.^[52]

In May 2022, the European Commission proposed a ban on oil imports from Russia.^[53] The proposal was reduced to a ban on oil imports by sea to appease Hungary, whose leader has befriended Putin and which gets 60% of its oil from Russia via pipelines.^[54] European oil pipeline supply from Russia is 800,000 barrels a day and is an exception to the sanctions with oil transit insurance bans being phased over several months. Germany and Poland have vowed to end pipeline deliveries.^[55]

Switzerland is a major hub for commodities trading globally. As such, about 80% of Russia’s commodity trading goes through Geneva and with a further estimated 40 commodities companies linked to Russia in Zug.^[56] Glencore, Gunvor, Vitol, Trafigura and Lukoil Litasco SA are oil and commodities trading firms with stakes in Rosneft and Lukoil, two major Russian oil companies.^[57][58][59] MMK (a Russian-based company in Lugano) is also a major player in the commodities/steel trading with Eastern Europe.^[60] On 8 March 2022, Shell announced its intention to withdraw from the Russian hydrocarbons industry.^[61][62]

Banking

In a 22 February speech,^[63] US president Joe Biden announced restrictions against four Russian banks, including V.E.B., as well as on corrupt billionaires close to Putin.^[64][65] UK prime minister Boris Johnson announced that all major Russian banks would have their assets frozen and be excluded from the UK financial system, and that some export licences to Russia would be suspended.^[66] He also introduced a deposit limit for Russian citizens in UK bank accounts, and froze the assets of over 100 additional individuals and entities.^[67]

The foreign ministers of the Baltic states called for Russia to be cut off from SWIFT, the global messaging network for international payments. Other EU member states had initially been reluctant to do this, both because European lenders held most of the nearly $30 billion in foreign banks' exposure to Russia and because China had developed an alternative to SWIFT called CIPS; a weaponisation of SWIFT would provide greater impetus to the development of CIPS which, in turn, could weaken SWIFT as well as the West's control over international finance.^[69][70] Other leaders calling for Russia to be stopped from accessing SWIFT include Czech president Miloš Zeman,^[71] and UK prime minister Boris Johnson.^[72]

Germany had resisted calls for Russia to be banned from SWIFT, citing the effect it would have on payments for Russian gas and oil; on 26 February, the German foreign minister Annalena Baerbock and economy minister Robert Habeck made a joint statement backing targeted restrictions of Russia from SWIFT.^[73][74] Shortly thereafter, it was announced that major Russian banks would be removed from SWIFT, although there would still be limited accessibility to ensure the continued ability to pay for gas shipments.^[75] Furthermore, it was announced that the West would place sanctions on the Russian Central Bank, which holds $630bn in foreign reserves, to prevent it from liquidating assets to offset the impact of sanctions.^[76]

On 26 February, two Chinese state banks—the Industrial and Commercial Bank of China, which is the largest bank in the world, and the Bank of China, which is the country's biggest currency trader—were limiting financing to purchase Russian raw materials, which was limiting Russian access to foreign currency.^[77] On 28 February, Switzerland froze a number of Russian assets and joined EU sanctions. According to Ignazio Cassis, the president of the Swiss Confederation, the decision was unprecedented but consistent with Swiss neutrality.^[78] The same day, Monaco adopted economic sanctions and procedures for freezing funds identical to those taken by most European states.^[79] Singapore became the first Southeast Asian country to impose sanctions on Russia by restricting banks and transactions linked to Russia;^[80] the move was described by the South China Morning Post as being "almost unprecedented".^[81] South Korea announced it would participate in the SWIFT ban against Russia, as well as announcing an export ban on strategic materials covered by the "Big 4" treaties to which Korea belongs—the Nuclear Suppliers Group, the Wassenaar Arrangement, the Australia Group, and the Missile Technology Control Regime; in addition, 57 non-strategic materials, including semiconductors, IT equipment, sensors, lasers, maritime equipment, and aerospace equipment, were planned to be included in the export ban "soon".^[82]

On 28 February, Japan announced that its central bank would join sanctions by limiting transactions with Russia's central bank, and would impose sanctions on Belarusian organisations and individuals, including President Aleksandr Lukashenko, because of Belarus' "evident involvement in the invasion" of Ukraine.^[84] According to The Wall Street Journal, payments for energy raw materials have been largely spared from these measures.^{[citation needed]} The Central Bank of Russia was blocked from accessing more than $400 billion in foreign-exchange reserves held abroad.^[42][85] Sergei Aleksashenko, the former Russian deputy finance minister, said: "This is a kind of financial nuclear bomb that is falling on Russia."^[86] EU foreign affairs chief Josep Borrell said that Western nations "cannot block the reserves of the Russian central bank in Moscow or in China".^[87]

On 1 March, the Grand and General Council of San Marino authorised the country's government to take sanctions against Russia, and rejected that the measures had a military content.^[88] The same day, the French finance minister Bruno Le Maire said that Russian assets being frozen by sanctions amounted to $1 trillion.^[89] South Korea announced it would stop all transactions with 7 main Russian banks and their affiliates, restrict the purchase of Russian treasury bonds, and agreed to "immediately implement" and join any further economics sanctions imposed against Russia by the European Union.^[90][91]

Following sanctions and criticisms of their relations with Russian business, many companies chose to exit Russian or Belarussian markets voluntarily or in order to avoid potential future sanctions.^[27] Visa, Mastercard, and American Express independently blocked Russian banks as of 2 March.^[92] Following Swiss sanctions on Russia, Credit Suisse issued orders to destroy documents linking Russian oligarchs to yacht loans, a move which led to considerable criticism.^[93]

Export

The US instituted export controls, a novel sanction focused on restricting Russian access to high-tech components, both hardware and software, made with any parts or intellectual property from the US. The sanction required that any person or company that wanted to sell technology, semiconductors, encryption software, lasers, or sensors to Russia request a licence, which by default was denied. The enforcement mechanism involved sanctions against the person or company, with the sanctions focused on the shipbuilding, aerospace, and defence industries.^[94][95]

On 20 March 2022, Australia banned the export of alumina, bauxite and other aluminium ores to Russia.^[96]

EU sanctions

On the morning of 24 February, Ursula von der Leyen, the president of the European Commission, announced "massive" EU sanctions to be adopted by the union. The sanctions targeted technological transfers, Russian banks, and Russian assets.^[97] Josep Borrell, the High Representative of the Union for Foreign Affairs and Security Policy, stated that Russia would face "unprecedented isolation" as the EU would impose the "harshest package of sanctions [which the union has] ever implemented". He also said that "these are among the darkest hours of Europe since the Second World War".^[98] President of the European Parliament Roberta Metsola called for "immediate, quick, solid and swift action" and convened an extraordinary session of Parliament for 1 March.^[99][100]

European impoundment of yachts

A 5 April 2022 article by Insider claims the total cost of yachts impounded throughout Europe to be over $2 billion. This amount includes the motoryacht Tango, seized pursuant to United States sanctions with Spanish assistance.^[101]

France

On 26 February, the French Navy intercepted Russian cargo ship Baltic Leader in the English Channel. The ship was suspected of belonging to a company targeted by the sanctions. The ship was escorted to the port of Boulogne-sur-Mer and was being investigated.^[102]

On 2 March 2022, French customs officials seized the yacht Amore Vero at a shipyard in La Ciotat. The Amore Vero is believed to be owned by the sanctioned oligarch Igor Sechin.^[103]

Two yachts belonging to Alexei Kuzmichev of Alfa Bank were seized by France on March 24.^[104]

Germany

On 2 March 2022, German authorities immobilized the Dilbar, owned by Alisher Usmanov.^[105][106] She is reported to have cost $800 million, employ 84 full-time crew members, and contain the largest indoor swimming pool installed on a superyacht at 180 cubic metres.^[107]

Italy

On 4 March, Italian police impounded the Lady M. Authorities believe the ship is owned by Alexei Mordashov.^[108] The same day, Italian police seized the yacht of Gennady Timchenko, the Lena, in the port city of Sanremo.^[109] The yacht was also placed on a United States sanctions list.^[110] On 12 March 2022, Italian authorities in the port of Trieste seized the Sailing Yacht A, known to be owned by Andrey Melnichenko. A spokesperson for Melnichenko vowed to contest the seizure.^[111]

Spain

In March 2022, the Spanish Ministry of Development (known by its acronym "MITMA") detained three yachts pending investigation into whether their true owners are individuals sanctioned by the European Union. The Valerie is detained in the Port of Barcelona; Lady Anastasia in Port Adriano in Calvià, Mallorca; and the Crescent in the Port of Tarragona.^{[112][113][114]}

United Kingdom

On 29 March 2022 Grant Shapps, the British secretary of state for transport, announced the National Crime Agency's seizure of the PHI. The yacht was docked at Canary Wharf and was about to leave.^[115][116]

Netherlands

On 6 April 2022 Dutch Minister of Foreign Affairs Wopke Hoekstra sent a letter on the subject of sanctions addressed to the House of Representatives. In it, he reported that while no Russian superyachts were at anchor in the Netherlands, twelve yachts under construction across five shipyards were immobilized to ascertain ownership, including possible beneficial ownership.^[117]

Aviation

The EU sanctions introduced on 25 February included a ban on the sale of aircraft and spare parts,^[118] and also required lessors to terminate the leases on aircraft placed with Russian airlines by the end of March.^[119]

Services and spare parts

On 2 March, Airbus and Boeing both suspended maintenance support for Russian airlines.^[120] On 11 March, China blocked the supply of aircraft parts to Russia.^[121] Business jet manufacturer Bombardier Aviation announced that, in addition to suspending after-sales service activities, it had cancelled all outstanding orders placed by Russian individuals or companies.^[122] As of April 2022, spare part and repair difficulties for the Safran/Saturn SaM146 engines used on the Sukhoi Superjet 100 were expected to force Russian airlines to ground the type.^[123] The lack of approved spare parts has also affected foreign aircraft flying into Russian airports.^[124]

In June 2022, Patrick Ky, Executive Director of the European Aviation Safety Agency (EASA), expressed concern about the safety of Western-made aircraft flying in Russia without proper access to spare parts or maintenance. He highlighted that risks increase over time and cited reports that Russia will be forced to cannibalise aircraft.^[125]

Leased aircraft

On 10 March, Russia passed legislation outlining conditions to impede the return of leased aircraft to foreign lessors, including the need for approval from a government committee and payment of settlements in Roubles.^[126] Many aircraft operated by Russian airlines had been registered with the Bermuda registry, which suspended airworthiness approvals on 14 March.^[127] The same day, Russia implemented a law allowing aircraft operated by Russian airlines to be re-registered with the Russian registry, effectively confiscating them from their overseas owners. Some 515 commercial aircraft, valued at approximately $10 billion, were leased by Russian airlines from foreign lessors prior to the sanctions.^[128] Lessors moved swiftly to repossess those few aircraft "stranded" outside Russia^[129] and reassigned some new aircraft due to be placed with Russian airlines, particularly Boeing 737 MAX that are now unlikely ever to be recertified by Russia.^[130] By 22 March, 78 Russian aircraft had been repossessed, amid speculation that some Russian airlines were cooperating with lessors in order to avoid jeopardising future relations.^[131] Rossiya Airlines, a subsidiary of Aeroflot, had reregistered all its fleet with the Russian registry by 29 March, and ensured that any international flights would use only Russian-owned aircraft.^[132]

By 30 March, Irish lessor AerCap had repossessed 22 of the 135 aircraft it had leased to Russian airlines, and 3 of the 14 engines on lease. It filed insurance claims totalling $3.5 billion for the remaining aircraft, many of which were "now being flown illegally by [its] former airline customers".^[133] Singapore-based lessor BOC Aviation had 18 aircraft worth $935 million on lease to Russian companies; it repossessed from Hong Kong one Boeing 747-8F leased to AirBridgeCargo but two other freighters were flown back to Russia contrary to explicit instructions, despite their insurance coverage and airworthiness certificates having been revoked.^[134]

On 31 March, Russian Deputy Prime Minister Yury Borisov declared that all leased aircraft still in Russia had been re-registered and would remain in Russia. This represents over 400 aircraft whose leases have been terminated.^[135] However, re-registration of aircraft without their owners' consent is a breach of ICAO standards.^[136]

Aeroflot gradually resumed international flights to "friendly" countries: to Kyrgyzstan from 14 March, Azerbaijan on 21 March, Armenia from 22 March, Iran from 2 April, Sri Lanka from 8 April,^[137] and Turkey and India from 6 May.^[138] On 2 June an Aeroflot A330 belonging to an Irish lessor was temporarily impounded by a commercial court in Sri Lanka, though the aircraft was subsequently allowed to return to Russia on 5 June.^[139]

On 13 May, Aeroflot announced that it had purchased 8 A330s from foreign leasing companies, under an exemption that allows the execution of a lease solely to obtain repayments.^[140] On 1 June, it emerged that five Russian airlines had kept a total of 31 aircraft outside Russia and returned them to lessors. Other airlines including Aeroflot have deposited money in special Rouble accounts to enable lessors to claim the amounts once sanctions are lifted.^[141]

Airspace

On 24 February 2022, Ukrainian airspace was closed to civilian aircraft a few hours before the Russian invasion started, on the basis of a notification from the Russian Ministry of Defence. The European regulator EASA issued a Conflict Zone Information Bulletin (CZIB) warning that civilian aircraft could be misidentified or even directly targeted.^[142]

On 25 February, the UK announced the closure of its airspace to Russian airlines.^[143] On 27 February, the EU and Canada closed their airspace to all Russian aircraft, including both commercial and private aircraft.^[144] Russia issued a reciprocal ban, forcing many airlines to reroute or cancel flights to Asian destinations.^[145] The US issued a similar ban on 1 March.^[146] On 8 March, Aeroflot suspended all its remaining flights to international destinations (except for Minsk, Belarus) due to airspace restrictions^[147] and to counter the "risk" of aircraft being repossessed by lessors.^[148] On 9 March, to avoid Russian airspace, Finnair started routing its flights to Asia over the North Pole, the first time a polar route has been used for commercial flights in nearly 30 years.^[149] An analysis of routes between Europe and Asia showed increased travel distances of between 1200 and 4000 km; the frequency of flights to some destinations has been reduced and other routes have been dropped.^[150]

By 29 March 2022, the following countries and territories had completely closed their airspace to all Russian airlines and Russian-registered private jets:^{[151][152][153][154]}

In addition to airspace closure under sanctions, on 11 April EASA blacklisted 21 Russian airlines on safety grounds, given that aircraft are being operated without airworthiness certificates, in breach of the Chicago Convention and international safety standards.^[170] EASA clarified that the Russian air transport regulator, Rosaviatsia, had failed to provide evidence that it has the capacity to perform the oversight activities required to ensure air safety.^[171] The US Federal Aviation Administration also downgraded Russia's safety rating, meaning that no new services to the US and no codeshares with US carriers are authorised.^[172]

In May 2022, the UK announced that Russian airlines would be prohibited from selling their landing slots at UK airports, valued at approximately £50 million.^[173] The slots were subsequently reallocated to other airlines.^[174]

At the end of May 2022, the Civil Aviation Administration of China (CAAC) closed its airspace to aircraft that have been re-registered with the Russian registry in breach of ICAO regulations and for which the airlines are thus unable to provide proper documentation.^[175]

Russian aircraft manufacturing industry

EASA revoked the type certificates of the Sukhoi Superjet 100, Tupolev Tu-204 and four other Russian aircraft types on 14 March, as well as approvals of maintenance organisations and third-country authorisations for Russian airlines. EASA also suspended all work on new certification applications, including the Irkut MC-21 airliner.^[176] Due to the need to source all aircraft components domestically, notably the Pratt & Whitney PW1400G engines which will be replaced by Russian-built Aviadvigatel PD-14 units, production of the MC-21 is expected to be delayed by 2 years. In the meantime, production of older and less fuel-efficient Russian-built aircraft such as the Tupolev Tu-214 and Ilyushin Il-96-400 will be stepped up, and a fuel subsidy introduced.^[177] The Sino-Russian CR929 wide-body aircraft programme, which was already in difficulty due to the diverging expectations of the two parties, is also expected to suffer significant delays or even cancellation.^[178]

On 7 June, Aeroflot announced plans to order 300 Russian-built aircraft, mostly the MC-21 and Superjet 100, as well as a smaller number of older Tupolev Tu-214s.^[179]

On 27 June, the Russian government announced details of a plan to bring the proportion of domestically produced aircraft to 80% of the Russian fleet by the end of the decade. Serial production of the SSJ-New with all-Russian components is expected to begin in 2023. Deliveries of the MC-21 are expected to start in 2024 and reach a delivery rate of 72 per year by 2029. To fill the gap, around 70 new Tu-214s will also be produced. For regional aircraft, the plan calls for 70 Ilyushin Il-114-300s, up to 140 UZGA TVRS-44 Ladoga twin turboprops, and more than 150 UZGA LMS-901 single-engined aircraft to be produced by the end of the decade.^[180]

On 29 June, the US government expanded its sanctions to cover United Aircraft Corporation (UAC) (the parent company of Irkut, United Engine, Tupolev, Ilyushin and others), with an exemption allowing UAC to export parts and services for civil aircraft not registered in Russia if necessary for aviation safety.^[181]

Aviation industry organisations and alliances

On 15 March, Aeroflot CEO Mikhail Poluboyarinov, targeted by EU sanctions, was removed from the IATA board of governors.^[182]

In April, the two Russian airlines that were members of global airline alliances both saw their memberships suspended: S7 Airlines from Oneworld and Aeroflot from SkyTeam.^[183]

U.S. "freeze and seize" policy

The main United States sanctions law, IEEPA, blocks the designated person or entity's assets, and also prohibits any United States person from transacting business with the designated person or entity. Specifically, 50 U.S.C. § 1705 criminalizes activities that "violate, attempt to violate, conspire to violate, or cause a violation of any license, order, regulation, or prohibition," and allows for fines up to $1,000,000, imprisonment up to 20 years, or both. Additionally, United States asset forfeiture laws allow for the seizure of assets considered to be the proceeds of criminal activity.

On 3 February 2022, John "Jack" Hanick was arrested in London for violating sanctions against Konstantin Malofeev, owner of Tsargrad TV. Malofeev is targeted for sanctions by the European Union and United States for material and financial support to Donbass separatists.^{[184][185][186][187][188][189][a]} Hanick was the first person criminally indicted for violating United States sanctions during the War in Ukraine.^[191]

According to court records, Hanick has been under sealed indictment in the United States District Court for the Southern District of New York since November 2021. The indictment was unsealed March 3, 2022. Hanick awaits extradition from the United Kingdom to the United States.^[192][193]

In the March 1, 2022 State of the Union Address, American President Joe Biden announced an effort to target the wealth of Russian oligarchs.

Tonight, I say to the Russian oligarchs and the corrupt leaders who’ve bilked billions of dollars off this violent regime: No more.

The United States — I mean it. The United States Department of Justice is assembling a dedicated task force to go after the crimes of the Russian oligarchs.

We’re joining with European Allies to find and seize their yachts, their luxury apartments, their private jets. We’re coming for your ill-begotten gains.^[194]

On March 2, 2022, U.S. Attorney General Merrick B. Garland announced the formation of Task Force KleptoCapture, an inter-agency effort.^[195]

On March 11, 2022, United States President Joseph R. Biden signed Executive Order 14068, "Prohibiting Certain Imports, Exports, and New Investment With Respect to Continued Russian Federation Aggression," an order of economic sanctions under the United States International Emergency Economic Powers Act against several oligarchs. The order targeted two properties of Viktor Vekselberg worth an estimated $180 million: an Airbus A319-115 jet and the motoryacht Tango.^[196] Estimates of the value of the Tango range from $90 million (U.S. Department of Justice estimate) to $120 million (from the website Superyachtfan.com).

On April 4, 2022, the yacht was seized by Civil Guard of Spain and U.S. federal agents in Mallorca. A United States Department of Justice press release states that the seizure of the Tango was by request of Task Force KleptoCapture, an interagency task force operated through the U.S. Deputy Attorney General.^{[197][198][199]}

The matter is pending in the United States District Court for the District of Columbia. The affidavit for the seizure warrant states that the yacht is seized on probable cause to suspect violations of 18 U.S.C. § 1349 (conspiracy to commit bank fraud), 50 U.S.C. § 1705 (International Emergency Economic Powers Act), and 18 U.S.C. § 1956 (money laundering), and as authorized by American statutes on civil and criminal asset forfeiture.^[200]

Other entities

On 9 March 2022, the New Zealand Parliament passed the Russia Sanctions Act 2022, which allows for sanctions to be placed on individuals connected to the 2022 Russian invasion of Ukraine and targets their assets including funds, ships, and planes. New Zealand also created a blacklist targeting senior Russian officials and oligarchs.^[201][202] On 6 April, New Zealand also imposed a 35% tariff on Russian products while restricting industrial exports to Russia.^[203][204]

The Bahamas, Antigua and Barbuda and Saint Kitts and Nevis also joined the list of imposing sanctions on Russia.^{[205][206][207]}

On 2 May Finnish consortium Fennovoima announced that it had terminated its contract with Russia's state-owned nuclear power supplier Rosatom for the delivery of a planned nuclear power plant in Finland.^[208]

Summary of sanctions by regions

Statistics on sanctions

Shifting of safe havens and sanctions evasion

Dubai

To avoid the impact of Western sanctions, close allies of Vladimir Putin and wealthy Russian oligarchs, fled to seek a financial safe haven. Lured by the United Arab Emirates' flexible visa program, many wealthy Russians moved their money to the UAE. Property purchases in Dubai by Russians surged by 67% in the first three months of 2022. Around 200,000 Russians were estimated to have left the country in the first 10 days of the war.^[209] Investigations revealed that private jets and yachts belonging to sanctioned Russian oligarchs and billionaires were found in places like Dubai and the Maldives. A number of private jets belonging to sanctioned Russians were also tracked flying back and forth between Moscow and Tel Aviv, and between Russia and Dubai.^[210][211] Russians also attempted to shift their wealth from Switzerland, London or the EU to Dubai. They looked to investments such as real estate and buying into funds that do not disclose ownership information. Many of them were not just buying properties in Dubai, but were also interested in full residence. The UAE offers long-term residence visas through its "golden visa" program, which could allow these oligarchs to live, work, and study in the UAE with full ownership of their business.^[212][213]

In May 2022, it was revealed that sanctioned Russian oligarchs and other officials invested in properties and businesses in Dubai. Due to this, European Parliament members suggested that the UAE should be blacklisted just like Iran, North Korea, and Burkina Faso. Citing lax anti-money laundering regulations in the UAE, European lawmakers also feared that the scale of money laundering there could compromise the EU's ability to counteract organized crime and corruption.^[214]

A Russian oligarch, Andrey Melnichenko was sanctioned by the European Union in March 2022, after claims that he attended a meeting with Putin on the day of the invasion. Following the sanctions, Italian authorities seized Melnichenko's $600 million Sailing Yacht A. Another yacht belonging to him, the $300 million Motor Yacht A was identified parked in a port in Ras al-Khaimah in the UAE.^[215] A $350 million Boeing 787 Dreamliner private jet belonging to Roman Abramovich was also grounded in Dubai and was to be seized by the US Department of Justice.^[216] Politicians and campaigners, including Danish MEP Kira Marie Peter-Hansen and campaigner Bill Browder, called for the UAE to be blacklisted for allowing the flow of "dirty money" and acting as a refuge for sanctioned Russians. An attorney and former FBI agent, Karen Greenaway pointed out that the Emirates had been placed on the FATF greylist, but was not taking enough measures against Russia.^[217][218]

On 23 June 2022, the Madame Gu superyacht, owned by sanctioned billionaire Andrey Skoch, was reported to have been docked at Port Rashid in Dubai since 25 March despite being designated as sanctioned property by the US.^[219] In June 2022, Russia’s wealthiest oligarch, Vladimir Potanin moved his $300 million superyacht, Nirvana, to Dubai. Potanin is head of Nornickel, because of which the US or Europe didn’t impose any sanctions on him by then. Experts said such a move could affect the market and disrupts supply chains. Potanin’s move to shift the luxury superyacht to Dubai’s Port Rashid was a precautionary measure.^{[220] [221]}

Switzerland

According to the Swiss Embassy in Moscow in 2022, Switzerland has long been "the most important destination worldwide for rich Russians to manage their wealth".^[222] The Helsinki Commission of the U.S. Congress referred to Switzerland as "a leading enabler of Russian dictator Vladimir Putin and his cronies".^[223] According to the Swiss Bankers Association, the amount held by Russian clients in Swiss banks in 2022 is between CHF 150 and 200 billion (between US$160 and 214 billion).^[224] As of May 2022, only CHF 6.3 billion had been frozen by the Swiss authorities.^[225]