2022 was an unprecedented year in the development of international financial and trade sanctions following Russia’s invasion of Ukraine in February 2022. The sanctions imposed on Russia by the UK, EU, US, Japan, Switzerland and others represent the most severe sanctions ever imposed on a major economy. For the UK and EU in particular, the breadth and speed with which such sanctions have been imposed on Russia is without parallel – and both jurisdictions are still working through practical issues that have arisen concerning the interpretation and enforcement of the sanctions. At the same time, the enforcement powers of UK and EU regulatory authorities have been expanded and the capacity of regulators to deal with the implementation and enforcement of sanctions is beginning to increase to match their expanded role.
In this article we focus on the UK and EU Russia sanctions introduced in 2022 – providing an overview of those sanctions and then looking forward to the likely developments in 2023.
