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This content was last updated on 22 April 2022

Please find below an overview of the five packages of sanctions measures the EU has imposed as from 23 February 2022 until to date, condemning the violation of Ukrainian sovereignty and territorial integrity by Russia.

Individual restrictive measures now apply to a total of 1093 individuals (including Vladimir Putin) and 80 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.

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

  • Export ban on dual-use items;
  • Prohibition to export goods and technology suited for use in oil refining;
  • 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 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 (including Rosneft and Gazprom);
  • Ban on imports from Russia of coal and other solid fossil fuels;
  • Ban on all Russian vessels from accessing EU ports;
  • Ban on imports of selected goods such as wood, cement, seafood and liquor.

All the EU legal acts that have been published in the EU Official Journal, however, until and up to date no consolidated legislation has been provided.

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).

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.

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.

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.

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

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 US sanctions towards Russia we kindly refer to the following website: UK sanctions relating to Russia – GOV.UK (www.gov.uk)

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

More information

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