EU sanctions measures against Russia (update)

This content was last updated on 26 July 2024.

Since 23 February 2022, the EU has progressively imposed sanctions against Russia in response to Russia’s violation of Ukraine’s sovereignty and territorial integrity. Below we provide an overview of the to date thirteen sanctions packages against Russia.

Individual restrictive measures now apply to a total of 1,718 individuals (including Vladimir Putin) and 419 entities and include an asset freeze and a prohibition on making funds available to the listed individuals and entities. In addition, a travel ban applicable to the listed persons prevents these individuals from entering or transiting through EU territory. The new listing criterion includes persons who benefit from the forced transfer of ownership or control over Russian subsidiaries of EU companies. Moreover, deceased persons can be kept on the asset freeze list.

In addition to these individual restrictive measures, the most important EU sanctions measures are:

• A ban on the purchase, import and transfer of crude oil and refined oil from Russia;
• Export ban on dual-use items, especially tighter export restrictions which might contribute to the technological enhancement of Russia’s defence and security sector;
• Prohibition to export goods and technology suited for use in oil refining and other EU industrial goods;
• Trade restrictions on aviation and space industry;
• Constraints to deal with transferable securities and money-market instruments;
• Restrictions on deposits, loans and credit;
• A ban on transactions with the Russian Central Bank;
• Enhanced sanctions and an investment ban in the energy-sector ;
• Ban on imports to the EU of iron, steel and aluminum products;
• Broad ban on direct and indirect dealings with 12 state owned entities (including Rosneft and Gazprom);
• Ban on imports from Russia of coal, other solid fossil fuels and LPG;
• Ban on all Russian vessels from accessing EU ports;
• Ban on imports of selected goods such as wood, cement, seafood and liquor;
• Ban on the import of gold, gold jewelry and non-industrial diamonds from Russia;
• New anti-circumvention tools allowing restrictions of exports to third countries, the obligation to contractually prohibit re-export of certain goods to Russia, closer monitoring of the sale of tankers to third countries and the imposition of more detailed attestation requirements and blacklisting companies outside of Russia as well;
• Prohibition on access to EU ports against vessels suspected of circumvention.
• Transit prohibition for certain sensitive goods.
• Ban on export of luxury goods, such as cars, including electric cars.
• Prohibition to provide enterprise and design related software to the Russian government or Russian companies.
• Expanding the list of restricted items that could contribute to the technological enhancement of Russia’s defence and security sector by adding components for the development and production of unmanned aerial vehicles (UAV); and
• Further restrictions on exports of goods which contribute in particular to the enhancement of Russian industrial capabilities, such as electrical transformers.

All the EU legal acts have been published in the EU Official Journal and are available in consolidated legislation. Below we have provided an overview of the contents of each sanctions package. This publication is provided for your convenience and does not constitute legal advice.

We recommend all businesses who are affected by sanctions and export control to familiarize themselves with these sanctions and ensure that internal compliance procedures are adequate and up-to-date. If you have any questions or would like to discuss the impact (and opportunities) under these sanctions, please feel free to reach out to us.

14^th package

On 24 June 2024, the EU adopted its 14th sanctions package against Russia, which “responds to the needs and findings on the ground, and tackles enforcement issues”, “target high-value sectors of the Russian economy, like energy, finance and trade, and make it ever more difficult to circumvent EU sanctions.”

For a total overview on the 14th package of new economic sanctions against Russia, please the following links:

• https://www.consilium.europa.eu/en/press/press-releases/2024/06/24/russia-s-war-of-aggression-against-ukraine-comprehensive-eu-s-14th-package-of-sanctions-cracks-down-on-circumvention-and-adopts-energy-measures/?utm_source=linkedin.com&utm_medium=social&utm_campaign=20240624-fac-russia-sanctions-14-package&utm_content=visual
• https://ec.europa.eu/commission/presscorner/detail/en/ip_24_3423

The new restrictions include:

1. Energy: a ban on re-exports of Russian liquefied natural gas (LNG) in EU waters.

2. Transport: measures against the shadow fleet moving Russian oil outside the price cap on Russian crude set by the Group of Seven (G7) nations.

3. Import-export controls: the EU introduced further restrictions on exports of goods which contribute in particular to the enhancement of Russian industrial capabilities (e.g. chemicals, including manganese ores and compounds of rare-earths, plastics, excavating machinery, monitors and electrical equipment), as well as further restrictions on the import of helium from Russia, which is a source of significant revenues for the regime.

4. Anti-circumvention: first of all, EU parent companies will be required to undertake their “best efforts” to ensure that their third-country subsidiaries do not participate in activities that undermine the sanctions set forth in Regulation 833/2014.

   On 22 November 2024 the EU Commission provided further guidance on what ‘best efforts’ should be understood to entail for EU parent companies when dealing with their non-EU subsidiaries: https://finance.ec.europa.eu/document/download/65560de8-a13a-4a58-a87c-ddd27b14e6c1_en?filename=faqs-sanctions-russia-best-efforts-obligation_en.pdf.

    Also, on 24 September 2024, the G7 (Canada, France, Germany, Italy, Japan, the United Kingdom, the United States and the EU) published its guidance document Preventing Russian Export Control and Sanctions Evasion: Updated Guidance for Industry. The aim of this document is to provide guidance to industry on preventing the diversion of sanctions measures, including through third countries: https://finance.ec.europa.eu/news/sanctions-vis-vis-russia-commission-publishes-g7-industry-guidance-preventing-sanctions-evasion-2024-09-24_en.

    Second, to help counter the re-exportation of battlefield goods found in Ukraine or critical to the development of Russian military systems, it was decided that EU operators selling such battlefield goods to third countries will need to implement due diligence mechanisms capable of identifying and assessing risks of re-exportation to Russia and mitigating them. In addition, EU operators transferring industrial know-how (IP) for the production of battlefield goods to third-country commercial counterparts will now have to include contractual provisions to ensure that such know-how will not be used for goods intended to Russia.

5. “No re-export to Russia” clause: this clause was introduced under the 12^th package. EU exporters are obliged to include in their contracts with counterparties in third countries other than Russia, except for partner countries, contractual provisions that (i) prohibit the re-export of inter alia certain sensitive items to or for use in Russia and (ii) provide for adequate remedies in case of contractual breach. Any breach of this contractual provision must in addition be reported to national competent authorities. New exemptions to the have been introduced. Also, it has been clarified that for contracts concluded before 19 December 19 the “No re-export to Russia” clause requirement would be considered fulfilled if the contract contains a general clause that prohibits exportation and re-exportation to jurisdictions targeted by EU sanctions and sets out adequate remedies in the event of a breach of that clause

6. Further sanctions listings: 47 new entities and 69 individuals were added to the EU sanctions list, bringing the total to 2,200. Some of the listed entities are located in third countries (China, Kazakhstan, Kyrgyzstan, Türkiye, and the United Arab Emirates) and have been involved in the circumvention of trade restrictions and engaged in the procurement of sensitive items used for example in the production of drones or providing material support for Russian military operation.

7. Extending exemptions to provide services & software to EU and Partner Countries subsidiaries in Russia: Article 5n of Regulation 833/2014 prohibits the provision of certain business services, enterprise management and software and industrial design and manufacture software to the Government of Russia and entities established in Russia (for example to subsidiaries of EU parent companies or Joint Ventures). The exemption that applied for the provision of such services and software intended for the exclusive use of entities established in Russia that are owned or controlled by a parent in the EU, the European Economic Area, Switzerland or a partner country, as listed in Annex VIII of Regulation 833/2014 (“Relevant Subsidiaries”), was initially scheduled to expire on 20 June 2024. This exemption, however, has been renewed until 30 September 2024. As from this date an authorization from the national competent authorities. 

8. Reinforcing enforcement: in addition to violation and enforcement problems and judgments handed down by national courts, EU Member States are now expressly required to inform each other and the European Commission on penalties applied for infringements of EU sanctions under the EU-Russia Sanctions Legal Framework (Regulations 269/2014 and 833/2014).

9. Promoting Voluntary Self-Disclosures (VSD): Although there no EU voluntary self-disclosure mechanism in place, the EU-Russia Sanctions Legal Framework (Regulations 269/2014 and 833/2014) now provide that penalties may take into account the voluntary, complete and timely self-disclosure of infringements of these sanctions as a mitigating factor, in accordance with respective national laws.

The EU is currently discussing approving a 15^th package of sanctions, which also includes sanctions on tankers carrying Russian oil.

13^th package

On 23 February 2024 the European Council adopted the 13^th sanctions package against Russia. The focus of this package is to tighten the restrictive measures against Russia’s military and defence sector, also targeting entities in third countries who supply equipment as well as those responsible for the illegal deportation and military re-education of Ukrainian children.

According to the EU press release, the package includes the following key measures (EU adopts 13th package of sanctions against Russia (europa.eu))

1. Targeting Russia’s military and defence sector:

The new listings include more than 140 companies and individuals from the Russian military-industrial complex, which among other things manufacture missiles, drones, anti-aircraft missile system, military vehicles, high-tech components for weapons, and other military equipment.

2. Sending a strong signal against Russia’s war effort partners:

The new listings target 10 Russian companies and individuals involved in the shipping of Democratic People’s Republic of Korea (DPRK) armaments to Russia. They also target the Defence Minister of the DPRK, as well as several Belarusian companies and individuals providing support to the Russian armed forces.

3. Fighting circumvention:

The new listings include a Russian logistics company and its director involved in parallel imports of prohibited goods to Russia, and a third Russian actor involved in another procurement scheme.

4. Strengthening EU action against Russia’s temporary occupation and illegal annexation of areas of Ukraine:

The new listings include six judges and 10 officials in the occupied territories of Ukraine.

5. Sanctioning violations of children rights:

The new listings also include 15 individuals and 2 entities involved in the forced transfer and in the deportation and the military indoctrination of Ukrainian children, including in Belarus.

The EU legal act has been published in the EU Official Journal: Council Regulation (EU) 2024/745 of 23 February 2024 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine (Council Regulation (EU) 2024/745 of 23 February 2024 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine (europa.eu)). We expect the EU Commission will soon provide a consolidated version of Regulation (EU) No 833/2014.

This publication is provided for your convenience and does not constitute legal advice.

12th package

On 18 December 2023 the European Council has adopted the 12th sanctions package against Russia. The focus of this package is to impose imposes additional import and export bans on Russia, measures that combat sanctions circumvention and close loopholes.

According to the EU press release, the package includes the following key measures (EU adopts 12th package of sanctions against Russia (europa.eu)):

1. Additional Sanctions Listings:
   Over 140 additional individuals and entities subject to asset freezes. This covers important economic actors but also actors in the Russian military, defence and IT sector. Furthermore, actors are targeted that orchestrated the illegal “elections” in the occupied territories, that participated in the force “re-education” of Ukrainian children and actors involved in spreading propaganda promoting Russia’s war of aggression.
2. Trade Measures:
   1. An import ban on Russian diamonds, more specifically on non-industrial diamonds from Russia. Moreover, raw materials for steel production, processed aluminium products and other metal goods will be subject to an import ban.
   2. Additional export restrictions on dual-use and advanced technological and industrial goods. In particular:
      • New export controls on dual use/advanced tech: chemicals, thermostats, DC motors and servomotors, machine tools and machinery parts.
      • New export bans on EU industrial goods, including machinery and parts, construction-related goods, processed steel, copper and aluminium goods, lasers, and batteries.
      • Addition of 29 Russian and third country entities, including entities registered in Uzbekistan and Singapore, to the list of entities associated to Russia’s military-industrial complex.
      • A prohibition to provide enterprise and design related software to the Russian government or Russian companies.
3. Stricter Asset Freeze Obligations:
   New listing criterion that includes persons who benefit from the forced transfer of ownership or control over Russian subsidiaries of EU companies. Moreover, it will be possible to keep deceased persons on the asset freeze list and Member States face tighter obligations to proactively trace assets of listed persons.
4. Energy Measures:
   The oil price cap is tightened by closer monitoring of the sale of tankers to third countries and the imposition of more detailed attestation requirements. Moreover, the package contains a new import ban on LPG.
5. Stronger Anti-Circumvention Measures:
   The scope of transit prohibitions in place is broadened, moreover operators will be obligated to contractually prohibit re-export of certain categories of sensitive goods. Furthermore, a new measure is introduced that requires the notification of certain transfers of funds out of the EU from EU entities owned by more than 40% by Russians or Russian entities.
6. Additional Measures:
   A set of derogations is introduced. Firstly, one allowing the EU Member States to decide to deprive in the public interest a listed person of funds or economic resources. Secondly, allowing compensation for damages to be paid by a newly listed insurance company, and thirdly, allowing the sale of EU companies by certain listed individuals or entities.
   We recommend all businesses who are affected by sanctions and export control to familiarize themselves with these new sanctions and ensure that internal compliance procedures are adequate and up-to-date. In particular, those business who source raw materials for steel production, processed aluminium products and other metal goods, should carefully consider the impact of their business operations. Also, in view of anti-circumvention, businesses are obligated to contractually prohibit re-export of certain categories of sensitive goods.

The EU legal act has been published in the EU Official Journal: Council Regulation (EU) 2023/2878 of 18 December 2023 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine (europa.eu). We expect the EU Commission will sone provide a consolidated version of Regulation (EU) No 833/2014.

This publication is provided for your convenience and does not constitute legal advice. Please also see our recent article on the sanction measures against Russia impacting the imports of iron and steel products: New sanction measures against Russia impact imports of iron and steel products (11th package).

11th package 

On 23 June 2023, the EU adopted its 11th sanctions package against Russia. This package introduces a new anti-circumvention tool, and imposes further trade, transport and energy-related restrictions as well as additional listings. The package includes: 

• Further listing of 71 individuals and 33 entities, including senior military officials, decision makers, persons involved in the illegal deportation of Ukrainian children to Russia, judges who took politically motivated decisions against Ukrainian citizens, persons responsible for the looting of cultural heritage, businesspersons, propagandist, as well as Russian IT companies providing critical technology and software to the Russian intelligence, banks operating in the occupied territories and entities working with the Russian armed forces. 
• Designation of third country entities, which allows the EU to impose an asset freeze and prohibition on making funds available to such persons and entities if they significantly frustrate the EU’s sanctions.   
• A new anti-circumvention tool, which will allow the EU to restrict the sale, supply, transfer or export of specified sanctioned good and technology to certain third countries that are considered to be at “continued and particularly high risk of circumvention”. This measure is intended as a ‘last resort’ measure to be used if other means of intervention prove insufficient. 
• Additional trade measures, such as: 
  • Extension of the transit prohibition for certain sensitive goods such as advanced technology and aviation-related materials; 
  • Restrictions on the export of further 15 technological items found on the battlefield in Ukraine or equipment needed to manufacture such items; 
  • Tightening of restrictions on import of iron and steel goods, including requiring importers to demonstrate that iron and steel products processed in third countries do not contain sanctioned Russian input – as of 30 September 2023; 
  • Prohibition to sell, license or transfer intellectual property rights and trade secrets regarding restricted goods, in order to prevent their manufacture in a third country in circumvention of the sanctions; 
  • Extension of the ban on export of luxury cars, including all new and second-hand cars with an engine size above 1.900 cm3, all electric and hybrid vehicles and yachts;  
  • A full ban on certain types of machinery components.
• Additional transport measures, such as: 
  • Prohibition on trucks with Russian trailers and semi-trailers from transporting goods to the EU; 
  • Prohibition on access to EU ports for vessels that engage in ship-to ship transfers in violation of the Russian oil import ban or the Oil Price Cap; 
  • Prohibition on access to EU ports for vessels that fail to notify the competent Member State authority at least 48 hours in advance of a ship-to-ship transfer within a Member State’s EEZ or within 12 nautical miles from the baseline of a Member State’s coast; 
  • Prohibition on access to EU ports for vessels that manipulate or turn off their navigation tracking system when transporting Russian oil subject to the import ban or price cap; 
• Additional energy measures, including: 
  • Lapse of the possibility to import Russian oil by pipeline for Germany and Poland;  
  • Strict and targeted derogations to the existing export bans to enable the maintenance of the Caspian Pipeline Consortium pipeline which transports Kazakh oil to the EU through Russia; 
  • Extension of the exception to the oil price cap for Sakhalin oil for Japan (until 31 March 2024). 

The 11th sanctions package also includes an extension of the media ban to five additional channels, additional provisions on information exchange and reporting, and provides temporary derogations, inter alia, to allow the sale of proprietary rights in a Russian joint venture, securities in specific listed entities and the provision of piloting services in certain situations.  

The measures of the 11^th package have a significant impact on imports of iron and steel products processed in third countries. Specifically, they concern the iron and steel products listed in Annex XVII of the amended Regulation (EC) No. 833/2014. From 30 September 2023, importers must hold a Mill Test Certificate (MTC). From 30 September 2023, when importing products, which have been processed in a third country, using iron and steel products of Annex XVII, other than those of the CN codes 7207 11, 7207 12 10 and 7224 90, an importer will have to prove that products used in such processing did not originate in Russia. If the products used in the processing are of Russian origin, the import of the products into the EU is prohibited. The ban on import of iron and steel products of Annex XVII processed in third countries, with inputs of goods of the CN code 7207 11 originating in Russia, will apply as from 1 April 2024. The ban on import of iron and steel products of Annex XVII processed in third countries, with input of goods of the CN codes 7207 12 10 and 7224 90 originating in Russia, will apply as from 1 October 2024.

For more information about this new rule, please read our article on the website:  ‘New sanction measures against Russia impact imports of iron and steel products (11^th package)’.

10th package

On 25 February 2023 – a year after Russia’s invasion of Ukraine, the EU adopted its 10th sanctions package against Russia. This package consist of additional listings as well as further trade and financial sanctions, including:

• The listing of 121 individuals and entities who are deemed instrumental in Russia’s war, through their military activities including development of drones used in the war, political decisions, the spreading of propaganda as well as those involved in inhumane deportations and forced adoptions of Ukrainian children.
• Measures taken against Iranian individuals and entities who are involved in the manufacture and supply of drones and components used by Russia’s military in the war, as well as members and supporters of Russia’s Wagner mercenary group and its activities in other countries.
• Additional export restrictions on sensitive dual-use and advanced technologies that contribute to Russia’s military, such as electronic components used in drones, missiles, helicopters and other weapons systems, rare earth metals and thermal cameras.
• Dual-use restrictions concerning 96 listed entities associated with Russia’s military industry, bringing the total number of these entities to 506.
• Additional export bans on goods which can easily be redirected for use by Russia’s military, such as:
  • vehicles, semi-trailers and special vehicles such as snowmobiles,
  • electric generators, binoculars, radars,
  • construction goods such as bridges, structures for buildings, fork-lifts trucks, cranes,
  • goods critical for Russia’s industrial capacity, such as electronics, machine parts, pumps,
  • industrial plants and goods used in the aviation industry, such as turbojets.
• Additional import bans on Russian high-revenue goods, including bitumen and related materials such as asphalt, and synthetic rubber and carbon blacks.
• Additional financial sanctions on the three Russian banks Alpha-Bank, Ros-Bank and Tinkoff Bank, as well as the National Wealth Fund of the Russian Federation and the Russian National Reinsurance Company.

The 10th sanctions package also includes a ban on Russian nationals from service on governing bodies of critical infrastructure companies of the Member States, a prohibition on Russian nationals and entities to book gas storage capacity in the EU, and measures to facilitate EU companies’ divestment from Russia.

Finally, building on the EU’s recent steps to target circumvention of the sanctions, the 10th package also includes additional reporting obligations concerning the assets of the Russian Central Bank, frozen assets, private flights between the EU and Russia and a prohibition on transiting dual-use goods and firearms to third countries via Russia.

Ninth package

On 16 December 2022, the EU adopted its 9th package of sanctions against Russia. This package includes:

• Individual sanctions against 200 additional persons and entities. These listings mainly target the Russian armed forces, defence industrial companies, political members, and key figures involved in Russia’s missile strikes against civilians, theft of Ukrainian agricultural products and kidnapping of Ukrainian children.
• Additional export bans on sensitive dual-use items and advanced technology. These bans include drones and drone engines, camouflage gear, additional chemical/biological equipment, riot control agents and additional electronic components used in Russia’s military systems. The export bans also apply to exports to third countries where there is a risk of diversion and military use in Russia.
• The most severe export restrictions are also extended to 168 additional Russian entities closely linked to the Russian military-industrial complex.
• New export bans and restrictions on items such as complex generator devices, laptop computers and computing components, printed circuits, radio navigational systems, radio remote control apparatus, aircraft engines and parts of engines, cameras and lenses.
• Additional restrictions are imposed on the provision on business services, which now also include market research and public opinion polling services, technical testing and analysis services, and advertising services.
• Transaction bans on three additional Russian banks, including the designations of Credit Bank of Moscow and Dalnevostochniy Bank and a full transaction ban on the Russian Regional Development Bank.
• A new investment ban concerning the Russian mining sector, with the exception of the mining of certain raw materials.
• Extended broadcasting ban on the four Russian media outlets NTV, Pervyi Kanal, Rossiya 1 and REN TV.

The 9^th sanctions package follows the recent restrictions imposed on Russian oil imports. With effect from 5 December 2022, it is prohibited to import Russian seaborne crude oil, affecting almost 90% of Russian oil exports to Europe. On the same date, the EU, together with the G7 and Australia, also agreed to cap the price of Russian seaborne crude oil at $60 in order to limit price surges and further reduce Russia’s revenues.

The 9^th package also clarified the derogations concerning the import of Russian crude oil. Hungary, Slovakia and Bulgaria all benefit from derogations, which allows these three Member States to import Russian crude oil under certain conditions. All Member States can furthermore refine Russian crude oil and re-export their diesel products to Ukraine to support Ukraine’s supply while its refineries are affected by the war.

Eighth package

On October 6, the EU adopted the 8th package of sanctions on Russia, which includes:

• A significant increase in individual sanctions against individuals directly or indirectly supporting Russia’s actions vis-à-vis Ukraine. According to the Commission’s Vice-President, the new listings target key decision makers, oligarchs, senior military officials and propagandists deemed responsible for undermining Ukraine’s territorial integrity.
• The extension of trade bans with Russia, which includes the addition of new products banned for export and import such as aviation items, or electronic components and specific chemical substances, also goods under the anti-torture Regulation, as well as the extension of the ban on providing services that could benefit Russia (e.g. financial, IT consultancy and other business services). In addition, there is also a ban on the export of coal, which includes cocking coal (which is used in Russian industrial plants), specific electronic components (found in Russian weapons), technical items used in the aviation sector, as well as certain chemicals. As to the import bans, it includes a ban on the import of Russian finished and semi-finished steel products, machinery and appliances, plastics, vehicles, textiles, footwear, leather, ceramics, certain chemical products, and non-gold jewelry. Additionally, it will become prohibited for EU nationals to sit on governing bodies of Russian state-owned enterprises (e.g. the Russian Maritime Register).
• The creation of a new category of sanctioned persons, in order to prevent the circumvention of EU sanctions. Persons likely to be placed on this list circumvent the sanctions by, for instance, buying goods in the Union before exporting them to a third country with the intention of then exporting them to Russia.

Seventh package

On 21 July 2022, the EU adopted a “maintenance and alignment package”, counting as EU’s 7th package of sanctions against Russia. The measures in the package aim to restrict Russia’s ability to finance its war against Ukraine as well as adjust and strengthen the existing sanctions measures. The package includes:

• An import ban on gold and gold jewellery, which is Russia’s most important export after energy. The import ban applies to gold originating in Russia and exported from Russia to the EU or any third country;
• An expansion of the goods and technologies subject to the dual-use export ban;
• A broader ban on access to EU ports. The ban has been extended to EU locks to combat circumvention by Russian-flagged vessels through canals;
• An expansion of the prohibition on accepting deposits. The prohibition now also includes deposits from legal persons, entities and bodies established in a third country but majority-owned by Russian nationals or residents;
• A disclosure requirement of EU assets. For the first time, it is required that designated persons and entities disclose their assets in the EU to make the asset freeze more efficient. Non-disclosure of EU assets will constitute a breach of EU sanctions law and may lead to criminal liability under the laws of the relevant Member States;
• Clarifications concerning exemptions to certain prohibitions, such as the asset freezeban on making funds available and transactions with public entities. These clarifications concern:
  • import or transport of natural gas oil, metals and iron ore,
  • import or transport of oil, including refined petroleum products,
  • import or transport of pharmaceutical, medical, agricultural and food products, including wheat and fertilizers,
  • transactions necessary for the wind-down of contracts, operations, joint ventures or sale of proprietary rights in EU entities,
  • access to judicial, or arbitral proceedings and the recognition or enforcement of judgments and awards.

The 7^th package also includes the designations of 58 individuals and 11 entities, including Sberbank and FORSS Group of Companies.

In response to the crisis in Ukraine, the EU also has imposed (further) restrictive measures against Belarus targeting the Belarusian financial sector and individuals. See for an update: Restrictive measures against Belarus – Consilium (europa.eu). For information on the US sanctions towards Russia we kindly refer to the following website: Ukraine-/Russia-related Sanctions | U.S. Department of the Treasury. For information on the UK sanctions towards Russia we kindly refer to the following website: UK sanctions relating to Russia – GOV.UK (www.gov.uk).

Sixth package

On 3 June 2022, the EU adopted a sixth package of sanctions on Russia, which includes:

• A ban on the purchase, import and transfer of crude oil (within six months) and refined oil products (within eight months) from Russia;
• More banks are disconnected from the international payment system SWIFT (Sberbank, Credit Bank of Moscow Russian Agricultural Bank and Belarusian Bank For Development And Reconstruction);
• To prevent propaganda and fake news, some Russian media companies are no longer allowed to broadcast in the EU;
• The export ban on dual-use goods is extended;
• The provision of a number of business services to Russia is banned. (accounting, public relations, consultancy and cloud services);
• More Russian and Belarusian persons and entities are being put on the sanctions list.

Impact of the ban on oil
As far as the impact on the EU is concerned, there are sufficient stocks worldwide to reach the market in the medium term. The limited transitions in the regulation will allow the EU and its partners to secure alternative supply routes in a timely manner, minimising the impact on global markets. However, Member States are particularly dependent on Russian oil, and carefully calibrated derogations have been granted to those most exposed. The EU is determined to end its dependence on Russian fossil fuels as soon as possible.

Financial and business services measures
Addressing these services will prevent the Russian Government and Russian companies from taking advantage of European services that facilitate their business. This includes, for example, accountants and consultants, on which many Russian companies rely. Additional EU guidance on this prohibition is expected.

Fifth package

On 8 April 2022, the EU adopted a fifth package of sanctions on Russia, which includes a ban on:

• Imports from Russia of coal and other solid fossil fuels;
• All Russian vessels from accessing EU ports;
• Russian and Belarusian road transport operators from entering the EU;
• Imports of other goods such as wood, cement, seafood and liquor;
• Exports to Russia of jet fuel and other goods;
• Deposits to crypto-wallets.

The additonal listed individuals include high-ranking Kremlin officials, oligarchs – Moshe Kantor, Boris Rotenberg and Oleg Deripaska -, and other prominent businesspeople involved in key economic sectors such as energy, finance, media, defence and arms industry.

The additional sanctioned entities include four major Russian banks (Bank Otkritie, Novikombank, Sovcombank, and VTB), a company active in the transport sector and owned by the Russian Federation, and companies in the military-defence industry whose technology or products have played a role in the invasion

Fourth package

On 15 March 2022, the EU adopted a fourth package of sanctions on Russia, which comprises:

• Restrictive measures on an additional 15 individuals (including Russian ‘oligarchs’) and 9 entities operating in the aviation, military and dual use, shipbuilding and machine building sectors;
• Enhanced energy-sector sanctions;
• Investment ban in the energy sector;
• Ban on imports to the EU of iron and steel products;
• Broad ban on direct and indirect dealings with 12 state owned entities and related affiliates (including Rosneft and Gazprom).

It should be noted that the above mentioned ban on direct and indirect dealings with 12 state owned entities appears to prohibit all transactions which would cover any commercial interaction, not just finance or investment transactions. This means it would cover sales of any equipment, software et, and services to those 12 state owned entities, and not only specifically mentioned items in the sanctions regulations.

Third package

On 28 February 2022 the EU imposed a third package of sanctions on Russia, which include:

• A ban on transactions with the Russian Central Bank;
• € 500 million support package to finance equipment and supplies to the Ukrainian armed forces;
• A ban on the overflight of EU airspace and on access to EU airports by Russian carriers;
• New sanctions on additional 26 persons and one entity.

On 2 March 2022, the EU has excluded the following seven Russian banks from SWIFT: Bank Otkritie, Novikombank, Promsvyazbank, Rossiya Bank, Sovcombank, Vnesheconombank (VEB), VTB Bank. This prohibition also applies to any legal person, entity or body established in Russia whose proprietary rights are directly or indirectly owned for more than 50% by the above-mentioned banks.

This should ensure that these banks are disconnected from the international financial system and harm their ability to operate globally.

New trade restrictions apply to the aircraft, aerospace, oil refinery and high-tech sectors. These sanctions measures contain exemptions, including grandfathering provisions, which are subject to authorization and notification requirements. On that same date, also restrictive measures on an additional 160 individuals were imposed (14 oligarchs and prominent businesspeople, and 146 members of the Russian Federation Council).

On 9 March 2022, the EU introduced further restrictive measures with regard to the export of maritime navigation goods and radio communication technology to Russia. Also, new asset freeze designations were added on 9 and 11 March, among them 8 Russian businesspersons.

Second package

On 25 February 2022 the EU decided on a further, second, package of individual and economic measures (covering also Belarus) to respond to the unprovoked and unjustified military aggression carried out by the Russian Federation against Ukraine. These sanctions measures cover Russia’s financial, energy, and transport sectors, as well restrictions on dual-use goods (technology sector) and export financing, among other steps.

In summary the European Council agreed to the following individual and economic measures:

• To sanction Vladimir Putin, President of the Russian Federation and Sergey Lavrov, Minister of Foreign Affairs of the Russian Federation. (Individual restrictive measures will apply to a total of 654 individuals and 52 entities, and include an asset freeze and a prohibition from making funds available to the listed individuals and entities. In addition, a travel ban applicable to the listed persons prevents these from entering or transiting through EU territory.)
• Financial sanctions further expanding the existing financial restrictions, thereby cutting Russian access to the most important capital markets.
• Energy sector: the EU will prohibit the sale, supply, transfer or export to Russia of specific goods and technologies in oil refining, and will introduce restrictions on the provision of related services.
• Transport sector: export ban covering goods and technology in the aviation and space industry, as well as a prohibition on the provision of insurance and reinsurance and maintenance services related to those goods and technology.
• Technology sector: further restrictions on exports of dual-use goods and technology, as well as restrictions on exports of certain goods and technology which might contribute to Russia’s technological enhancement of its defense and security sector.
• Visa policy: diplomats, other Russian officials, and business people will no longer be able to benefit from visa facilitation provisions, which allow privileged access to the EU.

First package

On 23 February 2022, the EU officially imposed the first package of sanctions against Russia, in response to Russia’s decision to recognize the non-government controlled Ukrainian regions of Donetsk (DNR) and Luhansk (LNR) as independent entities, and its subsequent decision to send Russian troops into these regions.

This first package included:

• Sanctions (asset freeze and travel ban) against 351 members of the Russian state Duma who voted for the recognition of the DNR and LNR;
• Sanctions (asset freeze and travel ban) against an additional 27 high profile individuals, including Russia’s Minister of Defense, and entities associated with the breakaway regions, including the Russian banks Bank Rossiya and PROMSVYAZBANK;
• An import ban on goods from the non-government controlled areas, restrictions on trade and investments relating to certain economic sectors of the DNR and LNR, a prohibition to supply tourism services and an export ban for certain goods and technologies suited for key sectors like transport, telecommunications and energy;
• A sectoral prohibition to finance the Russian Federation, its government and Central Bank in order to limit the ability of the

Russian government and state to access the EU’s capital and financial markets and services.
These sanctions measures include various grandfathering and wind-down provisions (some of them subject to prior notification to EU Member State Authorities).

Shortly before the adoptions of the 9^th package, the EU also took further steps to strengthen the enforcement of EU sanctions. On the 2 December the EU Commission published a proposal for a directive imposing certain rules on the definition and penalties regarding violations of EU sanctions and circumvention. The proposed directive call for harmonized rules across the Member States and stricter criminal penalties.

Finally, to limit Russia’s ability to finance itself through oil sales, the EU has already agreed to ban Russian crude oil by sea in the European Union from 5 December 2022. However, in order to allow developing countries to continue to be supplied, a cap on the price of oil will be put in place for third countries. The 8th package of sanctions lays down the legal basis for this price-cap, the principle of which has been adopted by the G7. Note that in parallel to these new measures, the sanctions applicable to Crimea, to Donetsk and Luhansk will be extended to non-government-controlled areas of Ukraine, including the oblasts of Zaporizhzhia and Kherson

This publication is provided for your convenience and does not constitute legal advice.

More information

If you have any questions concerning the impact of the sanctions measures on your company, or would like to discuss, please feel free to reach out to:

• Tim Hesselink (th@kneppelhout.nl)
• Marc Padberg (mpd@kneppelhout.nl)
• Ton Bendermacher (tb@kneppelhout.nl)
• Britt van Beveren (bb@kneppelhout.nl)