US, UK, And EU Announce Potential Sanctions Responses To A Ukraine Incursion

Sanctions measures have been proposed in several jurisdictions as a potential response to any prospective Russian military incursion into Ukraine. A sanctions response of the sort currently proposed would have significant implications for companies doing business in Russia or with Russian companies. This post discusses the current proposed Ukraine-related sanctions measures in the United States, the United Kingdom, and the European Union.

United States

On 12 January 2022, US Senator Bob Menendez (Chairman of the Senate Foreign Relations Committee) and other US Senators introduced the Defending Ukraine Sovereignty Act of 2022 (the "US Legislation"). The US Legislation authorizes (and in some cases requires) specified sanctions if the US President determines that the Russian government: (i) "is engaged in or knowingly supporting a significant escalation in hostilities or hostile action in or against Ukraine, compared to the level of hostilities or hostile action in