ASEAN speaks out against Russia’s invasion of Ukraine – Singapore issues sanctions and restrictions in relation to Russia

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ASEAN speaks out against Russia’s invasion of Ukraine – Singapore issues sanctions and restrictions in relation to Russia

ASEAN speaks out against Russia’s invasion of Ukraine – Singapore issues sanctions and restrictions in relation to Russia

March 7, 2022

The Association of Southeast Asian Nations (ASEAN) has on 3 March 2022 issued a statement calling for an immediate ceasefire or armistice and continuation of political dialogues that would lead to sustainable peace in Ukraine.

In Singapore, Minister for Foreign Affairs Dr Vivian Balakrishnan, had in a Ministerial Statement delivered in Parliament on 28 February 2022, stated Singapore’s intention to act in concert with other like-minded countries to impose appropriate sanctions and restrictions against Russia. The rare decision for Singapore to issue its own sanctions against Russia outside of United Nations Security Council directives follows the Russian veto of a draft United Nations Security Council Resolution deploring Russia’s aggression against Ukraine and demanding among other actions, that Russia withdraws its military forces from Ukraine. Singapore’s actions underline its strong stance in respect and support of international law, and of state sovereignty, political independence and territorial integrity of all countries.

Details of these sanctions and restrictions were released by the Ministry of Foreign Affairs on 5 March 2022.

The sanctions and restrictions imposed are aimed at limiting Russia’s capacity to conduct war against Ukraine and undermine its sovereignty, and fall broadly within the following two categories:

Export controls on items that can be directly used as weapons to inflict harm on or to subjugate the Ukrainians, and items that can contribute to offensive cyber operations; and
Financial measures targeted at designated Russian banks, entities and activities in Russia, and fund-raising activities benefiting the Russian government. It should be noted that digital payment token service providers are specifically prohibited from facilitating transactions that could help to circumvent these financial measures.

We set out below a summary of these sanctions and restrictions:

	Type of Sanction/Restriction	Source of Sanction/Restriction	Effect of Sanction/Restriction
1.	Export controls	Strategic Goods (Control) Order 2021 (SGCO)	All permit applications to Russia involving the following items will be rejected: all items on the List of Military Goods under the SGCO; and all items under the category codes of Category 3 - Electronics, Category 4 - Computers and Category 5 – Telecommunications and “Information Security” on the List of Dual-Use Goods under the SGCO.
2.	Financial measures	Monetary Authority of Singapore Act 1970	All financial institutions in Singapore, including banks, finance companies, insurers, capital markets intermediaries, securities exchanges, and payment service providers will be prohibited from: Entering into transactions or establishing business relationships with the four Russian banks listed below. Where there are existing business relationships, financial institutions must freeze any assets and funds of these four banks. – VTB Bank Public Joint Stock Company; – The Corporation Bank for Development and Foreign Economic Affairs Vnesheconombank; – Promsvyazbank Public Joint Stock Company; and – Bank Rossiya. Providing financing or financial services in relation to the export from Singapore or any other jurisdiction of goods subject to Singapore’s export controls on Russia. These goods comprise all items in the Military Goods List and specified categories in the Dual-Use Goods List of the SGCO in 1 above. Providing financial services in relation to designated Russian non-bank entities which are involved in activities in (b). Where there are existing business relationships, financial institutions must freeze any assets and funds of these designated activities. Details of these designated non-bank entities have yet to be released. Entering into transactions or arrangements, or providing financial services that facilitate fund raising by the Russian government, the Central Bank of the Russian Federation and any entity owned or controlled by them or acting on their direction or behalf (Russian Entities). The prohibitions apply to buying and selling new securities, providing financial services that facilitate new fund raising by, and making or participating in the making of any new loan to the Russian Entities. The Singapore Government and Monetary Authority of Singapore will also cease investing in newly issued securities of the Russian Entities. Entering into transactions or providing financial services in relation to the sectors of transport, telecommunications, energy and prospecting, exploration and production of oil, gas and mineral resources, in the breakaway regions of Donetsk and Luhansk Entering into or facilitating any transactions involving cryptocurrencies, to circumvent any of the above prohibitions in (a) to (e). This prohibition covers all transactions that involve cryptocurrencies and extend to the payment and settlement of transactions that relate to digital assets (such as non-fungible tokens).

We encourage all our clients (including investment funds managed by Singapore fund managers) to urgently assess their exposure to Russia, the implications resulting from these newly announced measures, and to ensure compliance with all applicable regulations and measures. Our Singapore team, together with our sanctions specialists from Dentons offices across the globe are well positioned to support our clients in navigating the complex area of sanctions compliance.

Dentons Rodyk thanks and acknowledges Practice Trainee Joli Cheah for her contributions to this article.

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ASEAN speaks out against Russia’s invasion of Ukraine – Singapore issues sanctions and restrictions in relation to Russia

ASEAN speaks out against Russia’s invasion of Ukraine – Singapore issues sanctions and restrictions in relation to Russia

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