Thanks to Russia, Cross-Border Sanctions Collaboration at All-Time High

Russia’s unprovoked invasion and continued aggression in Ukraine has led to an unprecedented level of collaboration by sanctions stakeholders across jurisdictions, agencies, and sectors. IFI is publishing a series of blogs to highlight this increased collaboration. In this first blog, we take a look at cooperation across borders and most notably by the REPO Task Force and Price Cap Coalition. 

The volume of information-sharing, meetings, and other coordination activities between jurisdictional authorities related to sanctions against Russia is by far the most extensive we have seen in a two-year period of any sanctions program in history. While most of this collaboration occurs outside of public view, it has become common to see multi-jurisdiction designation announcements, enforcement actions, advisories, and other joint press statements. Here are a few notable examples:

• The European Commission on February 13, 2024, issued a statement on the third Sanctions Coordinators Forum that gathered high-level representatives from all EU Member States, the United States, the UK, Ukraine, and 8 additional countries. The aim of the forum was to (1) identify ways to further disrupt Russia’s access to sensitive technology with potential military applications, notably by tackling different circumvention practices and emerging trends, and (2) reduce Russia’s revenue, in particular by reinforcing implementation of the oil price cap.
• The UK’s Office of Financial Sanctions Implementation (OFSI) and the US Office of Foreign Assets Control (OFAC) on November 15, 2023, issued a joint press release “One Year On: OFAC-OFSI Enhanced Partnership” discussing their ongoing commitment to deepen their collaboration to implement “robust, cutting-edge financial sanctions…[a]midst ever evolving threats to international security, prompted by Russia’s illegal and unprovoked invasion of Ukraine.”
• The US Department of the Treasury on May 16, 2023, issued a press release on the enhanced partnership between US and EU sanctions teams following a multi-day technical meeting in Brussels that included OFAC, the European External Action Service (EEAS), and the EC Directorate-General for Financial Stability, Financial Services and Capital Markets Union (DG FISMA). The press release highlighted “the unprecedented costs” imposed on Russia in response to its war of aggression against Ukraine.   

Two new institutions were created in 2022 to support multilateral collaboration on Russia sanctions, and each have made significant progress to enhance the overall impact and effectiveness of the sanctions, including with information-sharing to further improve enforcement.

• REPO Task Force: The Russian Elites, Proxies, and Oligarchs (REPO) Task Force was launched in March 2022 “to identify, locate, and freeze the assets of sanctioned Russians, with the aim of depriving the Kremlin of the funds it needs to fight its illegal war.” Participants include the Finance, Justice, Home Affairs, and Trade Ministries of Australia, Canada, France, Germany, Japan, Italy, the UK, and the United States, as well as the European Commissioners. The REPO Task Force has convened numerous meetings, issued several joint statements on their progress, and published a Global Advisory on Russian Sanctions Evasion.
• Price Cap Coalition: The oil price cap, introduced by the “Price Cap Coalition” comprising the G7, the European Union, and Australia in December 2022, has two key objectives: (1) constraining Russian revenues that could otherwise be used to fund Russia’s war of aggression against Ukraine, and (2) maintaining global oil flows and protecting energy security. The Price Cap Coalition and its members have issued several statements and guidance documents on price cap rules and policies, and most recently on February 1, 2024 published an Oil Price Cap Compliance and Enforcement Alert describing six evasion methods and recommendations for addressing them by relevant industry stakeholders.   

The EU’s 12th package of sanctions against Russia introduced a strengthened information sharing mechanism that will allow better identification of vessels and entities carrying out deceptive practices, such as ship-to-ship transfers used to conceal the origin or destination of cargo and automatic identification system (AIS) manipulations while transporting Russian crude oil and petroleum products.  

To mark the two-year anniversary of Russia’s invasion of Ukraine, the United States, UK, and EU are releasing a flurry designations and associated press releases, and we will almost certainly see a joint statement from the REPO Task Force on the group’s continued work similar to the one issued a year ago.