In the wake of Russia's invasion of the Ukraine early
last week, the European Union responded with the adoption of a
package of sanctions, most recently, yesterday on 2 March. In this
update, we provide clients with a high level guide to the sanctions
and reiterate the compliance obligations of regulated financial
services firms in respect of sanctions.
Introduction
The past week has seen the adoption of a number of European
Union ("EU") sanctions introduced by way
of EU Council Regulations "concerning restrictive measures
in respect of actions undermining or threatening the territorial
integrity, sovereignty and independence of Ukraine"
("EU Sanctions"). These EU Sanctions are
additional to the existing sanctions in place since 31 July 2014
which were imposed by the EU in response to Russia's actions
against Ukraine at that time. These sanctions have been extended on
a six monthly basis since that date (for more details in respect of
same, please see the
