On 14 October 2020, the EU designated under its asset freeze six Russian officials and one research institute, in response to the poisoning of Russian opposition leader Alexei Navalny in August 2020. Separately, it also designated Yevgeniy Viktorovich Prigozhin, a Russian businessman involved in breaches of the Libyan arms embargo.
The sanctions related to the Navalny poisoning1 were adopted under the EU’s sanctions framework targeting parties involved in the use and proliferation of chemical weapons.2 This sanctions regime, introduced in October 2018, was also used for the designation of parties involved in the Novichok poisoning of Sergei and Yulia Skripal and Nick Bailey in Salisbury (UK) in March 2018.
The six Russian officials who have been designated under the asset freeze and travel ban are Andrei Yarin (Chief of the Presidential Domestic Policy Directorate in the Presidential Executive Office), Sergei Kiriyenko (First Deputy Chief of Staff of the Presidential Executive Office), Sergei Menyailo (the Plenipotentiary Representative of the Russian President in the Siberian Federal District), Aleksandr Bortnikov (Director of the Russian Federal Security Service), and Pavel Popov and Aleksei Krivoruchko (both Deputy Ministers in the Ministry of Defence, respectively responsible for research activities and armaments). The entity made subject to an asset freeze is the State Scientific Research Institute for Organic Chemistry and Technology, a state research institute responsible for the destruction of chemical weapons stocks inherited from the Soviet Union.
Yevgeniy Prigozhin was designated3 under the EU’s Libya sanctions programme, due to his links with the private military company Wagner Group, which has been involved in multiple and repeated breaches of the UN arms embargo in Libya, including the delivery of arms and the deployment of mercenaries into Libya in support of the Libya National Army. Yevgeniy Prigozhin, and a number of his business interests, including in the catering sector, have previously been targeted by US sanctions, including in relation to interference in the 2016 US Presidential elections.
Under the EU asset freeze, all funds and economic resources in the EU belonging to or controlled by these parties must be frozen. Furthermore, no funds or economic resources may be made available – directly or indirectly – to or for their benefit. Economic resources are broadly defined to include anything that can be used to obtain funds, goods or services. Typical asset freeze exemptions may apply.
1 See Council Decision (CFSP) 2020/1482 of 14 October 2020 amending Decision (CFSP) 2018/1544 concerning restrictive measures against the proliferation and use of chemical weapons, and Council Implementing Regulation (EU) 2020/1480 of 14 October 2020 implementing Regulation (EU) 2018/1542 concerning restrictive measures against the proliferation and use of chemical weapons.
2 Further information on the EU's sanctions framework against the use and proliferation of chemical weapons can be found in our previous Client Alert
3 See Council Decision (CFSP) 2020/1483 of 14 October 2020 implementing Decision (CFSP) 2015/1333 concerning restrictive measures in view of the situation in Libya and Council Implementing Regulation (CFSP) 2020/1481 of 14 October 2020 implementing Article 21(2)of Regulation (EU) 2016/44 concerning restrictive measures in view of the situation in Libya.
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