On February 24, 2022, the Russian Federation launched a full-scale armed aggression against Ukraine in violation of the norms and principles of international law, in particular, enshrined in the Charter of the United Nations.
In response to such actions by the Russian Federation, the European Union has introduced new personal restrictive measures (sanctions) against those responsible or actively supporting or implementing steps and policies that undermine Ukraine's territorial integrity, sovereignty and independence, stability and security in Ukraine, create such threats, undermine the work of international organizations in Ukraine.
Thus, according to Article 2 of the Decision of the Council of the European Union 2014/145/CFSP on restrictive measures in connection with actions that undermine the territorial integrity, sovereignty and independence of Ukraine, threaten them (as amended), economic assets and funds that belong, are owned, maintained or controlled by natural or legal persons, organizations or bodies associated with them, must be frozen. Given the definition of "economic assets" and "funds" that are set forth in Art 1 of the mentioned Decision, it is about any assets, property, funds, etc.
Persons who have been included in Annex 1 to the mentioned Decision have a significant amount of valuable property, assets, funds on the territory of the Member States of the European Union, for example:
1) Russian oligarch Alisher Usmanov, whose sanctions were imposed on February 28, 2022, according to open sources, owns a villa in Munich, the Federal Republic of Germany, as well as seven villas on the island of Sardinia, Italy;
2) Russian oligarch Alexander Ponomarenko, whose sanctions were imposed on February 28, 2022, according to open sources, through a legal entity controls a villa worth more than 91 million euros in Saint-Jean-Cap-Ferrat, France;
3) Deputy Chairman of the Security Council of the Russian Federation Dmitry Medvedev, sanctions against whom were imposed on February 25, 2022, controls, in particular, land and a villa in Tuscany, Italy.
At the same time, it is extremely common for the persons to whom sanctions are applied are not the direct owners of the assets but they control them indirectly, through legal entities and individuals over whom the sanctioned persons have influence. In such cases, it is important for the competent authorities of the Member States of the European Union to identify and seize such assets as soon as possible under the control of sanctioned persons, taking into account the Sanctions Guidelines prepared by the General Secretariat of the Council of the Council.
Currently, there is information in open sources about isolated cases of freezing the assets of persons subject to EU sanctions.
It is possible to achieve the expected effect from the introduction of restrictive measures (sanctions) only if such sanctions are applied comprehensively and without the possibility of their avoidance, circumvention, etc.
In connection with the above,
PLEASE:
1. Identify as soon as possible economic assets and funds controlled by sanctioned individuals and legal entities.
2. Ensure as soon as possible the seizure of economic assets and funds belonging to, owned, held or controlled by natural or legal persons subject to sanctions, as well as associated organizations or bodies.