This content was last updated on 10 March 2023.
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 nine sanctions packages against Russia.
Individual restrictive measures now apply to a total of 1,214 individuals (including Vladimir Putin) and 108 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:
- A ban on the purchase, import and transfer of crude oil and refined oil from Russia;
- 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;
- Ban on the import of gold and gold jewellery from Russia.
All the EU legal acts that have been published in the EU Official Journal and available in consolidated legislation.
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 9th 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 9th 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 7th 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 9th 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:
