We recently reported that Norway had yet to enact ‘Stage 3’ sectoral sanctions against Russia and would likely do so imminently.  In light of the continued deteriorating situation in Ukraine, Norway enacted Forskrift 2014-08-15-1076 concerning restrictive measures that undermine or threaten Ukraine’s territorial integrity, sovereignty, independence and stability (the “Regulation“) on 15 August, which entered into force immediately.  

In a press release of the same date, the Norwegian Minister of Foreign Affairs Børge Brende stated that it was “vital that the international community stands united in its response to Russia’s actions” and that the Norwegian Government would “maintain a close dialogue with the business community to assess the consequences of the measures for the various sectors affected“.  The Ministry of Foreign Affairs (MFA) has opened a service telephone line for Norwegian companies affected by the new restrictive measures.

The Regulation brings Norway’s sanctions regime in respect of the Ukrainian crisis broadly in line with that of the EU.  The key aspects of the Regulation, as reported in the MFA press release, are as follows: 

  • The expansion of the list of designated persons that are subject to asset-freeze measures and travel restrictions to include a further 8 individuals and 12 entities. The criteria for the inclusion on the list is also expanded.  

 

  • A ban on imports from Crimea and Sevastopol and a ban on the issuing of loans or other forms of credit for the development of infrastructure in the transport, telecommunications and energy sectors, a ban on the issuing of loans or other forms of credit for the exploitation of oil, gas or mineral resources, and a ban on the sale or export of key equipment or technology to these sectors. 

  • A ban on the import and export of arms and defence-related products (List I) to and from Russia and the export of dual-use items and technology (List II) for military end-use in Russia.

  • Prior authorisation from the MFA is required for the export of certain categories of goods to the Russian petroleum sector. The export of products to be used for deep-water oil exploration and production, Arctic oil exploration and production, or in shale oil projects in Russia is prohibited.  Prior authorisation from the MFA is required for the provision of financing or other technical assistance related to these categories of goods.  

  • Finally, the Regulation introduces a ban on the purchase or sale of bonds, equities or similar financial instruments with a maturity exceeding 90 days issued by five listed Russian financial institutions.  The MFA press release confirms that authorisation can and will normally be given for the export of products if this is to honour obligations under contracts agreed prior to the entry into force of the Regulation.

The full text of the Regulation (in Norwegian only) may be found here.  The MFA has not yet confirmed whether they will issue an unofficial English translation of the Regulation.

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