come first
More than 40 years
legal expert
and national
Get in touch

EU’s 12th sanctions package against Russia

The EU High Representative, together with the European Commission have submitted the proposal for the 12th package of sanctions against Russia. The proposal will now be discussed by the 27 Member States, requiring unanimity to be endorsed. The core of the package is focused on enforcing the oil cap and a phased import ban on diamonds.

The following measures are also part of the proposal:

  1. Sanction over 120 additional individuals and entities for their role in undermining sovereignty and territorial integrity of Ukraine. These are actors from the Russian military, defence and IT sectors, as well as other important economic operators.
  2. Additional import bans on among others LPG and metals (pig iron, copper and aluminium wires, foil, tubes and pipes) and additional export bans (welding machines, chemicals and technologies used for military purposes, software license bans, lithium batteries, thermostats and motors and servomotors for drones).
  3. Tightening the oil price cap by introducing a) the requirement for attestation to include  itemized costs such as shipping and insurance costs b) enhance information sharing to identify vessels that are carrying out deceptive practices and c) introduce a notification system requiring authorization to sell or export tankers and second-hand carriers as a way of curtailing Russia’s shadow fleet of vessels it uses to transport oil outside the cap.
  4. Phased import ban on Russian diamonds and jewelry made from them, starting January 2024. Moreover, starting from March 2024 onwards an import ban will affect Russian diamonds of a higher weight that have been processed in third countries. Similarly, smaller stones will be so affected from September 2024 onwards.
  5. More goods may be added to the existing transit ban and additional companies in third countries may be listed (to avoid circumvention attempts).

The EU is taking further steps to prevent Russian influence in the financial and fintech industries by banning Russians from holding posts in European companies that provide crypto-asset wallets, accounts and custody services. Moreover, it is proposed that firms in Europe that are owned or controlled by Russian citizens or entities require authorization to transfer funds out of the EU. Another interesting factor is that if the proposal is approved, the sanctions list will include companies with which trade is restricted situated in countries outside Russia, such as Kazakhstan, Uzbekistan, Singapore and reportedly Hong Kong.

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)

More information

Should you have any questions regarding the content of this article, please feel free to reach out to our sanctions and export control lawyers:

Articles and customer stories within this specialist area