Russia Imposes Economic Sanctions Against Turkey

On November 28, 2015, President Putin signed the Decree No. 583 (the "Decree"), authorizing certain economic sanctions against the Republic of Turkey. In addition to the Decree, the Russian government issued on November 30, 2015 the Resolution No. 1296 (the "Resolution"), which provides details of the imposed sanctions.

Duration of the Sanctions

The duration of the sanctions is not determined. Both the Decree and the Resolution entered into force immediately after the publication (on November 28, 2015 and December 1, 2015, respectively) and will apply until canceled.

A. TARGETS OF THE SANCTIONS

1. GOODS AND PRODUCTS

Certain goods originated from Turkey (a list of which is determined by the Russian government) are banned or restricted from being imported to the territory of the Russian Federation.

So far, the list of banned goods published by the Russian government includes various agricultural products and food (chicken and turkey meat by-products, certain vegetables and fruits, flowers, salt and gum). The total ban for importation of these goods from Turkey into the Russian Federation comes into effect on January 1, 2016.

Exceptions

The goods imported for personal use in an amount permitted by the laws of the Eurasian Economic Union are excluded from the scope of these sanctions.

2. COMPANIES / CITIZENS

2.1.  Ban of Works / Services Provided by Turkish Companies

Companies under the jurisdiction of Republic of Turkey will be prohibited or restricted to provide certain works and render certain services on the territory of the Russian Federation. The list of such works and services will be issued by the Russian government (as of December 11, 2015, such list has not been published yet).

Exceptions

In December 2015, the Russian government is anticipated to issue a list of certain contracts entered into or to be entered into with the Turkish companies (for delivery of goods, provision of works and services) to which the sanctions will not apply;

Based on the text of the Decree, the sanctions should not apply to the subsidiaries of the Turkish companies incorporated in any jurisdiction other than Turkey.

3. CROSS-BORDER MOVEMENT

3.1. Ban of Charter Flights and Restrictions for Road and Sea Transportation

Starting from December 1, 2015, a ban on charter flights between Russia and Turkey is introduced.

The number of the bilateral road transportation permits to be issued to the Turkish transportation companies for 2016 will be limited to 2000.  The Russian Ministry of Transport is authorized, when necessary, to annul partially or fully the permits that have been already issued to the Turkish carriers for 2016. 

Further measures for strengthening of seaport control and transport security related to the Azov-Black Seas basin are anticipated for implementation by the Russian government.

Exceptions

Charter flights from Turkey delivering Russian citizens back to Russia are permitted.

3.2. Suspension of Visa-Free Regime

Starting from January 1, 2016, Turkish citizens travelling to Russia will be required to obtain a visa.

Exceptions

Visa-free entry will continue to have effect for Turkish citizens having Russian temporary residence permit or permanent residence permit and Turkish diplomatic and consular staff, and their families living in Russia.

3.3. Restrictions on Tourism

Travel operators and tourist agencies are recommended to refrain from selling to Russian citizens tours and related services for visits to Turkey.

4. ECONOMIC COOPERATION

The following Russian-Turkish projects have been suspended:

• Activities of the Russian-Turkish Intergovernmental Commission on Trade and Economic Cooperation;
• Negotiation and drafting process for the Bilateral Agreement between the Russian Federation and the Republic of Turkey on Trade in Services and Investments and the Middle-Term Program for Economic, Trade, Scientific, Technical and Cultural Cooperation for 2016-2019; and
• Establishment of the Russian-Turkish Fund for Financing Investment Projects in Russia and Turkey.

B. OTHER CONTROL MEASURES OF RUSSIAN AUTHORITIES

In line with the adopted sanctions in respect of Turkish goods, the Russian Federal Customs Service, the Federal Service on Surveillance for Consumer Rights Protection and Welfare (Rospotrebnadzor) and the Federal Service for Veterinary and Phytosanitary Surveillance (Rosselkhoznadzor) have already significantly enhanced the monitoring of the certain products originating from Turkey, not only agricultural products and food, but also baby clothes, furniture and household chemicals.  According to the official publications of the Russian authorities, the mentioned measures are introduced due to the non-compliance of Turkish goods with the Russian quality requirements.