RuAssetsWatch: Monitoring Initiatives to Confiscate Russian Assets for the Recovery of Ukraine 

Detailed description of the situation and analysis – September 2023

• The U.S. Departments of Treasury and Justice gathered in Washington, D.C., members of the Russian Elites, Proxies and Oligarchs (REPO) Task Force to reinforce sanctions efforts and support ongoing initiatives to confiscate the assets of Russian oligarchs. 
• International experts have presented convincing arguments that it is the multibillion-dollar frozen sovereign assets of the Russian Federation located in foreign jurisdictions that should be used to rebuild Ukraine’s critical infrastructure, residential buildings, schools and hospitals, as well as to compensate victims of Russian aggression.
• The EU continues its policy of strengthening control over the enforcement of sanctions and preventing violations of the sanctions regime. The European Commission hasissued a guidance for exporters on checking business partners for the risk of Russian sanctions
  circumvention. In particular, the guidance sets out what European exporters should do for due diligence of trade transactions to avoid violating EU sanctions.
• The EU is preparing to introduce a new, 12th package of sanctions against Russia. New restrictive measures, which could be presented as early as next month, are likely to include a ban on imports of Russian diamonds, and possibly a proposal to use the proceeds of the frozen assets of the Russian Central Bank to support Ukraine.
• The International Working Group on Russian Sanctions (the “Yermak-McFaul Group”) has released a paper “Using Energy Sanctions to Shorten the War”. Inter alia, the experts proposed to strengthen compliance with the price caps on Russian oil and limit Russia’s use of the “shadow fleet” of tankers.
• The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has imposed sanctions on five entities and two individuals from Iran, China, Hong Kong, Turkey, and the UAE involved in the procurement of sensitive spare parts for Iran’s
  unmanned aerial vehicle (UAV) program.
•  The United States arrested a Russian citizen for illegally purchasing a significant amount of US-made dual-use microelectronics for delivery to Russia. The U.S. Department of Justice reported he violated the law by using a network of shell companies to smuggle
  US dual-use technologies to Russia, including sights, night vision goggles, thermal optics and weapons systems.
•  ARMA has finally opened the Register of Seized Assets and the SPFU has launched a test operation of the Register of Sanctioned Assets. These measures will improve the efficiency of managing these assets and ensure public control over the work of the authorised state bodies.
• ARMA also put forward a legislative initiative to improve the process of managing seized assets: to remove the provision requiring the manager to coordinate its actions with the owner of the seized property.

The material was prepared with the support of the International Renaissance Foundation within the framework of the project “Advocacy for the Green Recovery of Ukraine through Increased Support for Ukraine and Weakening of Russian Influence in the EU”. The material reflects the position of the authors and does not necessarily reflect the position of the International Renaissance Foundation.