Russia Sanctions Tracker - EU
10 October 2024
This tracker is a high-level summary of the measures imposed by EU following Russia's invasion of Ukraine in February 2022.
This tracker is a high-level summary of the measures imposed by the EU following Russia's invasion of Ukraine in February 2022. In the current circumstances, the status of these measures are subject to change on a daily basis. Certain measures were in place prior to February 2022 and these are not included in this tracker. Whilst every effort has been made to ensure the accuracy and completeness of this summary at the date of publication, no reliance should be placed on its content and it does not constitute legal advice. Please refer to the primary sources of the restrictions for their full content.
Selected EU guidance and consolidated lists can be found under "useful links" at the bottom of the page.
This tracker was last updated on 10 October 2024.
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Date of imposition |
Sanction imposed |
Summary |
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8 October 2024
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New framework for imposition of asset freezes, prohibitions to make funds available and travel bans. |
The Council of the EU has established a new framework and legal basis for restrictive measures against individuals and entities responsible for destabilising activities against the EU and its Member States.
The framework sets out the criteria determining which persons and entities are to be listed; the criteria focus on actions that undermine or threaten democracy, the rule of law, stability, or security within the EU, its Member States, international organizations, or third countries. The key actions include:
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13 September 2024 |
Notices to designated persons |
The EU has published three notices for the attention of designated persons:
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Asset freeze – removals |
The entries for five deceased persons and two other persons, as well as one duplicate entry, have been removed from the list of designated persons in the Annex to Regulation (EU) No 269/2014:
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5 September 2024 |
Updated FAQs – Provision of Services |
The EU Commission has updated a Russia sanctions FAQ on the provision of services. The FAQ clarifies that nationals of EU Member States are subject to the prohibition to provide services even if the services are provided a an employee of an EU mother company to a subsidiary in Russia (see FAQ 37). |
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Updated FAQs - Asset freeze and prohibition to make funds and economic resources available |
The EU Commission has updated its Russia sanctions FAQs on asset freezes and prohibitions to make funds and economic resources available. In particular, the FAQs explain what a firewall is (see FAQ 42) and explain how aggregate ownership should be considered when determining whether an entity is owned by listed persons (FAQ 8). |
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5 August 2024 |
Belarus: Asset Freeze |
The EU Council has imposed restrictive measures against 28 individuals. |
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26 July 2024 |
Updated FAQs – Import, Purchase and Transfer of Listed Goods |
The EU Commission has updated its Russia sanctions FAQs on import, purchase and transfer of listed goods. In particular the FAQs explain what the newly introduced status of “partner countries for the importation of iron and steel” in Art. 3g(1)(d) means for the import and purchase of iron and steel products processed in third countries (FAQ 12). |
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Updated FAQs – Export-related restrictions for dual use goods and advanced technologies |
The EU Commission has updated its Russia sanctions FAQs on export related restrictions for dual use goods and advanced technologies. In particular the FAQs list the partner countries (the U.S., Japan, the United Kingdom, South Korea, Australia, Canada, New Zealand, Norway, Switzerland, Liechtenstein and Iceland) to Council Regulation 833/2014 and detail the benefits they enjoy pursuant to the Regulation. The EU Commission has also updated the Correlation Annex (Annex VII) which accompanies the Regulation. |
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24 July 2024 |
Updated FAQs – Central Securities Depositories |
The EU Commission has updated its Russia sanctions FAQs on central securities depositaries. In particular the FAQs:
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Updated FAQs - Chemicals |
The EU Commission has updated its Russia sanctions FAQs on chemicals. In particular FAQs 2, 3. 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16, 17, 18, 19, 20, 22, 23, 25 have been updated. |
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23 July 2024 |
In view of Russia's continuing actions destabilising the situation in Ukraine, the Council decided to renew the restrictive measures for a further 6 months, until 31 January 2025. |
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15 July 2024 |
New FAQ – 'no export to Russia' clause |
The EU Commission has launched a new set of FAQs on the 'no export to Russia clause' under Article 12g of Regulation 833/2014. |
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2 July 2024 |
Updated FAQs – Provision of Services |
The EU Commission has updated its Russia sanctions FAQs on the Provision of Services. In particular the FAQs:
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Updated FAQs – Divestment from Russia |
The EU Commission has updated its Russia sanctions FAQs on Divestment from Russia. In particular the FAQs explain why the derogations in Article 12b(1) and (2) of Council Regulation 833/2014 were introduced (see FAQ 1). |
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Updated FAQs – State-owned Enterprises |
The EU Commission has updated its Russia sanctions FAQs on State-owned Enterprises. In particular the FAQs explain why the exemption in Article 5aa of Council Regulation 833/2014 cannot apply to Sovcomflot after its listing in Council Regulation 269/2014 (see FAQ 16). |
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Updated FAQs – General Questions |
The EU Commission has updated its Russia sanctions General FAQs. In particular the FAQs explain that the prohibitions, derogations and exemptions in Council Regulation 269/2014 and Council Regulation 833/2014 operate independently and must be complied with as such (see FAQ 18 and FAQ 19). |
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New FAQs – Targeted Vessels |
The EU Commission has launched a new set of FAQs on Targeted Vessels in relation to Article 3S of Council Regulation 833/2014. The FAQ explains that a vessel, targeted in Annex XLII, laden with dangerous or polluting goods at the date of targeting, such as oil, can receive port access and services for a unique emergency port call for the offloading of the dangerous or polluting goods on board at the date of the targeting of the vessel within a reasonable time, and in any case not later than 30 days from the date of targeting. |
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| 24 June 2024 |
EU's 14th package of restrictive measures European Council press release (asset freeze) and press release (other measures). European Commission press release and Q&A |
The EU has introduced its 14th package of sanctions against Russia, which includes the following:
For a detailed update on the 14th package please see our briefing: 14th sanctions package against Russia: anti-circumvention measures and LNG export ban. The relevant Council Regulations can be accessed at the following links:
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Asset freeze – new listing (additions to Annex of Decision (CFSP) 2019/797) |
The EU council has imposed restrictive measures against the following 6 individuals for their role in cyber attacks affecting information systems in EU member states:
The restrictions are made under the EU cyber sanctions regime but each of the 6 individuals are either or both a Russian national or a member of a hacker group backed by the Russian Federal Security Service (FSB). |
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27 May 2024 |
Asset freeze – new listing (additions to Annex of Decision 2014/145/CFSP) |
The EU Council has imposed restrictive measures against two individuals and one entity:
These individuals and entity have been added to the Annex of the Council Decision 2024/1508 for conducting propaganda actions targeted at civil society in the EU and its neighbouring countries, distorting and manipulating the facts in order to justify and support Russia's war of aggression against Ukraine. |
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27 May 2024 The EU's new package of restrictive measures against those responsible for human rights violations |
In force from 27 May 2024 |
The EU Council has established an new framework for restrictive measures against those responsible for serious human rights serious human rights violations or abuses, repression of civil society and democratic opposition, and undermining democracy and the rule of law in Russia. The key provisions include:
The Regulation contains the following Annexes:
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Individuals or entities listed in Annex IV will be subject to an asset freeze. Those listed in Annex IV will include those who:
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Asset freeze – new listings (additions to Annex IV Regulation 2024/1485) |
One entity and 19 individuals have been added to the EU's list of persons subject to an asset freeze. The 19 individuals are also subject to a travel ban. These listings target those responsible for systematic abuses and ill-treatment of political prisoners in Russia, specifically in relation to the death of Alexei Navalny and the sentencing of Oleg Orlov and Alexandra Skochilenko. The new listings include:
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17 May 2024 |
Council Regulation (EU) 2024/1428 – Amendment to Regulation (EU) No 833/2014 Additions to Annex XV |
The EU Council has suspended the broadcasting activities of four media outlets:
These entities have been added to Annex XV of Regulation (EU) No 833/2014 by virtue of their role supporting and justifying the war in Ukraine. |
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14 May 2024 |
Updated FAQs - Media |
The EU Commission has updated its Russia sanctions FAQs on Media. In particular, the FAQs:
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24 April 2024 |
Penalties for sanctions breaches: breach of EU sanctions added to the list of 'EU crimes' |
The EU Council has adopted, and since published, an EU Directive which adds the violation and circumvention of EU sanctions to the list of 'EU crimes'. The new Directive sets out definitions for the violations which are punishable as 'EU crimes'. These include not freezing funds, not adhering to travel bans or arms embargoes, transferring funds to designated persons, doing business with state owned entities of designated states, and providing financial services or legal advice in violation of sanctions. The new law introduces minimum rules for the enforcement of, and penalties relating to, the above sanctions violations in member states. The penalties include a maximum of five years imprisonment and dissuasive fines to be issued by national judges. The Directive will come into force on 15 May 2024. After this, member states have 12 months to transpose the EU Directive into their national legislation. |
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18 April 2024 |
Updated FAQs - Oblasts |
The EU Commission has updated its Russia sanctions FAQs on Oblasts. The FAQs explain how operators assess which areas in the Donetsk, Kherson, Luhansk and Zaporizhzhia oblasts are subject to restrictions (see FAQ 1), and the restrictions and conditions on banks processing financial transactions in connection with trade done in the Donetsk, Kherson, Luhansk and Zaporizhzhia oblasts (see FAQ 4). |
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Updated FAQs – Import, Purchase and Transfer of Listed Goods |
The EU Commission has updated its Russia sanctions FAQs on the Import, Purchase and Transfer of Listed Goods. In particular the FAQs explain what the newly introduced status of “partner countries for the importation of iron and steel” in Art. 3g(1)(d) means for the import and purchase of iron and steel products processed in third countries (see FAQ 12). |
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12 April 2024 |
Updated FAQs – Reporting on Outgoing Transfers |
The EU Commission has updated its Russia sanctions FAQs on reporting obligations surrounding transfers involving Russian-owned entities outside the EU. In particular, the FAQs clarify the application and scope of Article 5r of EU Council Regulation 833/2014 (see FAQ 1, 2, 3, 4, 5, 8, 9 , 11, 13, 15 and 16). The FAQs also explain the criteria for "indirect transfer of funds out of the EU" (see FAQ 6); the minimum threshold amount when cumulative operations are involved (see FAQ 7); the criteria to determine indirect ownership (see FAQ 10); and the information financial institutions utilise to identify a legal person, entity or body referred to in Article 5r paragraph 1 (see FAQ 12). The FAQs announce the EU Commission has published a reporting template (see FAQ 14). |
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25 March 2024 |
Updated FAQs – State owned enterprises |
The EU Commission has updated its Russia sanctions FAQs on state owned enterprises, in particular in respect of providing insurance coverage to a vessel calling into a port owned by an entity listed in Annex XIX, and paying out an insurance claim for damage under the policy. – see FAQ 6 and FAQ 6a. |
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22 March 2024 |
Asset freeze – additions Global Sanctions Regime – restrictive measures against serious human rights violations and abuses |
The EU Council have placed restrictive measures on 33 individuals and 2 entities linked to the imprisonment of the Russian opposition politician, Alexei Navalny. |
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12 March 2024 |
Asset freeze: extension of restrictive measures |
The EU Council has decided to prolong the restrictive measures targeting those responsible for undermining or threatening the territorial integrity, sovereignty and independence of Ukraine for another six months, until 15 September 2024. The EU Council also decided not to renew the listings of three individuals and remove nine deceased persons from the list, as follows:
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1 March 2024 |
Updated FAQs – Restrictions on Diamonds |
The EU Commission has updated its Russia sanctions FAQs on restrictions on diamonds, in particular in respect of:
These updates are in response to various countries expanding their restrictions on the import of Russian diamonds following the G7 statement last year – see FAQ 6, FAQ 8, FAQ 9, FAQ 10 and FAQ 12. |
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23 February 2024 EU Commission Press Release European Council Press Release |
Asset freeze: new listings |
An additional 106 individuals and 88 entities have been added to the EU's list of persons subject to an asset freeze. |
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Trade restrictions: goods which could contribute to the enhancement of Russian industrial capacities - amendment |
A new exception has been added confirming that for CN codes 8504 10, 8504 21, 8504 22, 8504 23, 8504 31, 8504 40, 8504 50 and 8504 90, the existing prohibitions shall not apply to the execution until 25 May 2024 of contracts concluded before 24 February 2024. |
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Trade restrictions: entities supporting Russia's military/industrial complex – additions |
27 new entities were added to the list in Annex IV of those directly supporting Russia's military and industrial complex in its war of aggression against Ukraine. They will be subject to tighter export restrictions concerning dual use goods and technologies, as well as goods and technology which might contribute to the technological enhancement of Russia's defence and security sector. |
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Trade restrictions: items which might contribute to Russia's military and technological enhancement or to the development of its defence and security sector – amendment |
The list of items (Annex VII, Part B) which are subject to existing export restrictions has been expanded to include: components used for the development and production of drones, such as electric transformers, static converters and inductors found inter alia in drones, as well as aluminium capacitors, which have military applications, such as in missiles and drones and in communication systems for aircrafts and vessels. |
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Trade restrictions: Russian iron and steel - amendment |
The list of partner countries referred to in Article 3g(1) has been updated to include Switzerland, Norway and the United Kingdom. |
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23 February 2024 |
EU's "13th package" of restrictive measures EU Commission Press Release European Council Press Release |
The EU has introduced its 13th package of sanctions, which includes the following:
Further detail on the 13th package will be added to this tracker in due course. The relevant Council Regulations can be accessed here (amending Regulation 833/2014) and here (implementing Regulation 269/2014). |
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12 February 2024 |
Financial restrictions: management of reserves and assets of the Central Bank of Russia - amendments (amendment to Article 5A, Regulation 833/2014) |
The existing prohibition on transactions related to the management of reserves as well as of assets of the Central Bank of Russia has been amended, as follows. A new exception has been added to confirm that the existing prohibition does not apply to transactions carried out on or after 28 February 2022; From 15 February 2024, central securities depositories holding assets and reserves for/on behalf of the Central Bank of Russia (incl. the Russian National Wealth Fund) with a total value exceeding EUR 1 million are required to apply the following rules regarding such cash balances:
Central securities depositories shall report to the Commission and to their national supervisory authorities, by 30 June of each year, on the total amount of such cash balances, revenues and net profits. |
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6 February 2024 |
Updated FAQs – Software |
The EU Commission has updated its Russia sanctions FAQs on software, in particular in respect of the prohibition of certain business-relevant services to the Russian government and the types of software covered by the prohibition in Art.5n(2b) – see FAQ 1, FAQ 2, FAQ 3 and FAQ 4. |
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26 January 2024 |
Updated FAQs – Public Procurement |
The EU Commission has updated its Russia sanctions FAQs on public procurement, in particular in respect of ongoing contracts and new contracts and the relationship between Article 5k of Council Regulation (EU) 833/2014 and Article 2 of Council Regulation 269/2014 - see FAQ 11 and FAQ 49. |
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3 January 2024 |
Asset freeze: new listings |
1 individual and 1 entity have been added to the EU's list of persons subject to an asset freeze. The new listings include:
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18 December 2023 EU's "12th package" of restrictive measures EU Q&A EU Commission Press Release European Council Press Release |
Energy-related goods (Annex II) – amendments to exceptions / derogations (insurance) |
An existing exception and derogation are replaced, as follows:
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Financial restrictions: investment in Russian energy sector – new derogation (amendments to Article 3a) |
A new derogation is added in respect of Article 3a(1)(b), permitting competent authorities to authorise any activity which is necessary to ensure the operation of a deep-water offshore gas project in the Mediterranean Sea in which a legal person, entity or body listed in Annex XIX was a minority shareholder before 31 October 2017 and remains so, provided that the project is solely or jointly controlled or operated by a legal person incorporated or constituted under the law of a Member State. |
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Various restrictions: amendments to derogations in respect of the Paks II project (various) |
Amendments to various derogations to include specific reference to the Paks II project, a nuclear power plant project in Hungary, including: Article 2(4)(c), Article 2a(4)(c), Article 3ea(5)(d), Article 3g(7), Article 3i(3c), Article 3k(5)(c), Article 5k(2)(a), Article 5l(2)(d), Article 5n(10)(f) |
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Trade restrictions: Russian iron and steel – amendments (amendments to Article 3g, new Annex XXXVI |
Iron and steel products processed in a third country: In respect of iron and steel products processed in a third country, there is no longer the requirement to provide evidence of the origin of the iron and steel inputs used for processing if the product is imported from a "partner country for importation of iron and steel" as listed in Annex XXXVI. The Annex XXXVI countries are: Switzerland and Norway Other Russia iron and steel products: Updated import volume quotas for products with CN codes 7207 10 or 7224 90 to which the prohibitions will not apply. For products with CN codes 7207 10:
For products with CN codes 7224 90:
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Trade restrictions: various – origin of goods subject to restrictions (various) |
The following existing prohibitions now applies irrespective of whether or not the relevant goods originate in the EU:
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Trade restrictions: goods which generate significant revenues for Russia (Annex XXI) – new exceptions and derogations (amendments to Article 3i) |
Introduction of new derogations and exceptions to the existing prohibition, as follows:
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Trade restrictions: goods which could contribute to the enhancement of Russian industrial capacities - amendment (amendments to Article 3k, new Annex XXXVII) |
Introduction of a new provision prohibiting the transit via the territory of Russia of the goods and technology as listed in Annex XXXVII, exported from the EU. This new prohibition is subject to the existing exceptions in Article 3k. Introduction of new exceptions:
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Trade restrictions: Russian crude oil and petroleum products – extension of derogations (amendments to Article 3m) |
A number of existing derogations have been extended:
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Trade restrictions: transport services for crude oil or petroleum products (amendments to Article 3n) |
Introduction of a new requirement for service providers with no access to the purchase price per barrel to collect itemised price information for ancillary costs as provided by operators further up the supply chain of Russian crude oil or petroleum product trade, and provide such information to counterparties and competent authorities on request |
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Trade restrictions: Russian crude oil and petroleum products – information sharing (new Article 3na) |
To facilitate the implementation and enforcement of Articles 3m and 3n, the Commission and Member States shall periodically share information with each other with a view to further identify vessels and entities of concern carrying out one or more deceptive practices while transporting Russian crude oil and petroleum products. |
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Trade restrictions: Russian diamonds (new Article 3p and Annexes XXXVIIIA and XXXVIIIB) |
Introduction of the following prohibitions in respect of Russian diamonds:
Exceptions for goods listed in Part C of Annex XXXVIIIA for the personal use of natural persons travelling to the EU and not intended for sale. Derogation available for the loan of cultural goods. In respect of the prohibitions listed at 2 and 3 above:
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Trade restrictions: tankers for the transport of crude oil or petroleum products (new Article 3q) |
Introduction of a new prohibition on the sale or transfer of ownership, directly or indirectly, of tankers for the transport of crude oil or petroleum products listed in Annex XXV, falling under HS code ex 8901 20, whether or not originating in the EU, to Russian person/entity or for use in Russia. Any change in ownership from a Member State national/entity to a third country of any tankers for the transport of crude oil or petroleum products listed in Annex XXV falling under HS code ex 8901 20 must be immediately notified to the competent authority where the EU owner is resident/national/established. Any sale or transfer of ownership of tankers for the transport of crude oil or petroleum products listed in Annex XXV falling under HS code ex 8901 20 under the paragraphs above after 5 December 2022 and prior to 19 December 2023 shall be notified to the competent authorities before 20 February 2024. |
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Financial restrictions: new loans or credit – amendments to exceptions (amendments to Article 5 and Article 5a) |
Introduction of a new condition for the use of the exceptions to the prohibitions in Article 5(6) and (7), and Article 5a(2) and (3) namely notification to the national competent authority within three months of the new loan/credit or drawdown (as relevant). |
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Financial restrictions: transactions with state-owned entities – amendment to exceptions/derogations (amendment to Article 5aa) |
Amendments to existing derogations and exceptions:
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Financial restrictions: crypto service providers |
Introduction of a ban on Russian nationals or residents, directly or indirectly, owning or controlling, or holding any post in the governing bodies of any EU entities which provide crypto-asset wallet, account or custody services from 18 January 2024. |
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Trade restrictions: professional services – software (amendments to Article 5n; new Annex XXXIX) |
The existing prohibition on the provision of market research and public opinion polling services, technical testing and analysis services and advertising services now applies to the direct and indirect provision on those services.
Introduction of a new prohibition on the provision of technical assistance, brokering services or other services, financing or financial assistance related to the existing professional services restrictions. Introduction for a new derogation application to all restrictions for services which are for the exclusive use of Russian persons/entities that are owned by, or solely or jointly controlled by, an entity incorporated or constituted under the law of a Member State, the EEA, Switzerland or a partner country as listed in Annex VIII. |
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Financial restrictions: Russian-owned EU entities – transfer of funds (new Article 5r) |
From 1 May 2024, any entities established in the EU which is directly or indirectly owned more than 40% by:
From 1 July 2024, EU financial institutions must report to its competent authority on a quarterly basis any transfer of funds exceeding 100 000 EUR out of the EU initiated on behalf of any person/entity listed above. Competent authorities shall use the information reported to them to identify transactions, entities and business sectors that indicate a serious risk of breaches or circumvention of, or use of funds for purposes incompatible with the EU's sanctions on Russia. |
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Derogations: divestment from Russia - amendment |
Certain existing derogations for the purposes of divestment from Russia have been extended
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Trade restrictions: restrictions on re-exports (new Article 12g) |
Introduction of a new requirement for exporters to contractually prohibit re-exportation to Russia and re-exportation for use in Russia, as well as adequate remedies for breach of such provisions, when selling, supplying, transferring or exporting to a third country, with the exception of partner countries listed in Annex VIII to this Regulation:
Exporters are required to notify their competent authority if they become aware of a breach of the above provisions by their third-country counterparty. Exception for the execution of contracts concluded before 19 December 2023 until 20 December 2024 or until their expiry date, whichever is earlier. |
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Trade restrictions - entities supporting Russia's military/industrial complex – additions (amendments to Annex IV) |
29 new entities were added to the list in Annex IV of those directly supporting Russia's military and industrial complex in its war of aggression against Ukraine. They will be subject to tighter export restrictions concerning dual use goods and technologies, as well as goods and technology which might contribute to the technological enhancement of Russia's defence and security sector. |
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Trade restrictions: import and export restrictions – amendments (various) |
Expansion of the lists of various categories of goods/technology which are subject to import and export restrictions/prohibitions:
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Asset freeze – additions (additions to Annex I, Regulation 269/2014) |
61 individuals and 86 entities have been added to the EU's list of persons subject to an asset freeze. These listings primarily target the military and defence sectors, but also include important economic actors. The new listings include:
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Asset freeze: new ground for designation – compulsory transfer of Russian subsidiaries (amendment to Article 3, Regulation 269/2014) |
Introduction of a new criteria for designation:
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Asset freeze: designation – death of designated persons (amendment to Article 3, Regulation 269/2014) |
Introduction of a new provision which permits the European Council to maintain the designation of deceased persons where their delisting would undermine the EU's Russia sanctions. |
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Asset freeze: new derogations (new Articles 5a and 5b, Regulation 269/2014) |
Introduction of two new derogations permitting the release of frozen funds or economic resources:
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Asset freeze: new derogations – specific designated persons/entities (amendments to Article 6b, Regulation 269/2014) |
Introduction of various grounds to the release of frozen funds/economic resources belonging to the following entities in specific circumstances:
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Asset freeze: competent authorities – circumvention (amendments to Article 8) |
By 31 October 2024, Member States shall identify the national authorities competent to identify and trace funds and economic resources belonging to, or owned, held or controlled by, any designated persons, located in their jurisdiction, with a view to preventing or detecting instances of a breach or circumvention. |
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14 December 2023 |
Upcoming sanctions: EU's 12th package of restrictive measures – adoption of sanctions package |
In a press release issued by the European Council, it was reported that the EU has adopted the 12th package of sanctions. No further detail was provided. |
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6 December 2023 |
G7 Leaders' Statement: sanctions on Russian diamonds and other future measures |
The G7 leaders published a statement following a (virtual) meeting on 6 December 2023. As part of that statement, they provided further details regarding their intention to introduce sanctions on Russian diamonds, which will comprise:
The G7 leaders repeated their call for third parties to immediately cease providing material support to Russia’s aggression, or face severe cost.
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15 November 2023 |
Upcoming sanctions: EU's 12th package of restrictive measures - proposal submitted to EU Council |
The High Representative and the European Commission have submitted a proposal for the 12th package of restrictive measures to the EU Council.
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27 October 2023 |
Upcoming sanctions: EU's 12th package of restrictive measures – remarks by President von der Leyen (announced but not yet published or implemented)
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In her opening remarks at the joint press conference with President Michel following the meeting of the European Council of 27 October 2023, President von der Leyen referred to EU's upcoming 12th package of restrictive measures:
The EU is continuing to focus on properly implementing and effectively enforcing existing sanctions. |
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26 October 2023 |
Updated FAQs – Central Bank of Russia |
The EU Commission has updated its Russia sanctions FAQ in respect of the Central Bank of Russia , in particular in respect of the so-called "exit tax" which is payable as a precondition for allowing EU companies to divest from Russia. |
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12 October 2023 |
Oil Price Cap: Price Cap Coalition statement and maritime safety advisory |
The Oil Price Cap Coalition (Australia, Canada, the European Union, France, Germany, Italy, Japan, the United Kingdom, and the United States) have issued the following documents in respect of the price caps on seaborne Russian oil: Statement on actions taken to enforce price caps for seaborne Russian-origin oil and petroleum products: This states that the Coalition is focusing on supporting compliance and enforcement of the policy, noting that Russian oil tax revenue was down 45% from January -August this year relative to 2022. The statement also underscores the risks of violating price cap rules and highlights that the US is taking steps to action to impose sanctions on two entities and identify vessels as property in which those entities have an interest. Maritime Safety Advisory for the Maritime Oil Industry and Related Sectors: This advisory outlines best practices industry stakeholders can adopt to reduce risks while promoting the safe flow of oil on the market, and builds on previous guidance by the Coalition (details of which are in the advisory). By adopting the recommendations in the advisory and previous guidance documents, industry stakeholders can reduce their exposure to possible risks associated with recent developments in the maritime oil trade. |
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2 October 2023 |
Updated FAQs - various |
The EU Commission has updated its Russia sanctions FAQs by adding 11 FAQs on the prohibition on imports of iron and steel products processed in third countries which incorporate iron and steel inputs from Russia - see Article 3g(1)(d)). The EU Commission has also updated Russia sanctions FAQs on dual use goods - see FAQ 1, FAQ 12, FAQ 13, FAQ 42 and FAQ 46. |
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1 October 2023 |
Media Restrictions – extensions of existing measures (Article 2f and amendment to Annex XV) |
The existing prohibition on the broadcasting of content has been extended to include:
This took effect from 1 October 2023. (See entries from 3 April 2023, 25 February 2023 (tenth package) and 16 December 2022 for more information.) |
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13 September 2023 |
Asset freeze measures: renewal/extension European Council Press Release |
The Council has renewed the Russian sanctions contained in Regulation 269/2014 (i.e. the asset freeze measures) for another six months. The measures will now apply until 15 March 2024. The Council did not renew the listings of four individuals: Farkhad Akhmedov; Aleksandr Aleksandrovich Shulgin; Grigory Viktorovich Berezkin; and Georgy Ivanovich Shuvaev. These measures provide freezing of assets, a ban on making funds or other economic resources available to the listed individuals and entities; and travel restrictions for natural persons. |
| 12 September 2023 |
Updated FAQs – Import, purchase and transfer of listed goods |
The EU Commission has updated its FAQs on import, purchase and transfer of listed goods. The FAQ explains that Russian nationals are prohibited from temporarily bringing personal goods and vehicles listed in Annex XXI and subject to prohibitions into the Union, for example for touristic travel (See FAQ 13). There is a limited exemption for the purchase of goods in Russia for the personal use of nationals of Member States and their immediate family members. |
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Asset freeze - additions Global Sanctions Regime - restrictive measures against serious human rights violations and abuses
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The EU Council have placed restrictive measures on six individuals responsible for serious human rights violations in the Russian federation and in occupied Ukrainian territory. Those now subject to an asset freeze and travel ban participated in the politically motivated court proceedings or torture of Vladyslav Yesypenko, a journalist who was sentenced to 6 years in prison. The individuals now subject to an asset freeze and travel bans are:
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7 September 2023 |
European Commission Guidance for EU Operators: circumvention due diligence |
The European Commission has published guidance providing a general overview of the due diligence expectations to prevent the circumvention of Russia sanctions. This outlines:
In addition to this guidance, the Commission has published lists of sanctioned high-priority battlefield items and economically critical goods (list updated on 18 October 2023) to support due diligence and effective compliance by exporters and targeted anti-circumvention actions by customs and enforcement agencies of partner countries determined to prevent that their territories are being abused for circumvention of EU Russia sanctions purposes. |
| 3 August 2023 |
Belarus: New Restrictive Measures Amendments to Regulation 765/2006 |
The EU has imposed targeted restrictive measures, namely the following:
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Belarus: Asset Freeze |
The EU has imposed new restrictive measures against 38 individuals and 3 entities from Belarus which provide a substantial source of revenue or support for the Lukashenka regime. Those subject to sanctions are:
Those listed are responsible for serious human rights violations, contribute to the repression of civil society and democratic forces as well as those who benefit from and support the Lukashenko regime. |
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2 August 2023 |
Updated FAQs – oil price cap and oil imports |
The EU Commission has updated its FAQs:
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28 July 2023 |
Asset Freeze – additions |
7 individuals and 5 entities have been added to the EU's list of persons subject to an asset freeze. The individuals are:
The entities are:
The designations target those responsible for conducting a digital information manipulation campaign called RRN (Recent Reliable News). |
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26 July 2023 |
Updated FAQs - various |
The EU Commission has updates its FAQs available here:
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24 July 2023 |
Updated FAQs - various |
The EU Commission has updated its FAQS:
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20 July 2023 |
Asset Freeze - additions |
5 individuals have been added to the EU's list of persons subject to an asset freeze. These individuals are said to be involved in Iran's provision of military support for Russia through the development and delivery of Unmanned Aerial Vehicles to Russia. The individuals are:
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18 July 2023 |
Updated FAQs – various |
The EU Commission has updated its FAQs available here. Please refer to the FAQs below for updates:
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6 July 2023 |
Updated FAQs – various |
The EU Commission has updated its FAQs available here. Please refer to the FAQs below for updates:
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30 June 2023 |
Updated FAQs - various |
The EU Commission has updated its FAQs available here. Please refer to the FAQs below for updates:
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23 June 2023 EU's "11th package" of restrictive measures EU Q&A EU Commission Press Release European Council Press Release |
Asset Freeze – additions |
71 individuals have been added to the EU's list of persons subject to an asset freeze. This includes members of a working group established by President Putin tasked with coordinating efforts of the Russian Federation to support the war against Ukraine, judges who took politically motivated decisions, directors of museums responsible for the looting of cultural heritage and senior military officials. 33 entities have been added to the EU's list of persons subject to an asset freeze, including:
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Asset freeze – new derogations (amendments to Article 6b, Regulation 269/2014) |
Amendment of an existing derogation to permit the disposal of securities by an EU entity which is currently/previously controlled by VTB Bank or the National Settlement Depository, subject to certain conditions. New derogations to permit member state authorities to authorise the release of frozen funds/economic resources:
[* This appears to be an error] |
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Asset freeze – further criterion for designation (amendments to Article 3(1), Regulation 269/2014) |
Further criterion for designation have been added, as follows:
The recitals to the Regulation provide that "Indications of cases of frustrating the Union’s restrictive measures could include, inter alia, the fact that the main activity of a third country operator consists of purchasing restricted goods in the Union that reach Russia, the involvement of Russian persons or entities at any stage, the recent creation of a company for purposes related to restricted goods reaching Russia, or a drastic increase in the turnover of a third country operator involved in such activities". |
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Asset freeze – exceptions and reporting (various, Regulation 269/2014) |
New exception to the asset freeze measures for funds or economic resources that are needed for the provision of pilot services to vessels in innocent passage as defined by international law which are necessary for reasons of maritime safety (Article 6f). Amendments to the reporting obligations in Article 8:
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Trade restrictions: export (amendments - various) |
Expansion of the existing export restrictions to include a prohibition on the sale, license or transfer of intellectual property rights and trade secrets relating to the following goods or technology to any person/entity in Russia or for use in Russia:
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Trade restrictions: export |
Extension of the existing export restrictions to include a prohibition on the transit via Russia of the following goods/technology exported from the EU:
Existing exceptions will apply, for example for humanitarian purposes, medical or pharmaceutical purposes. Certain new exceptions have been introduced, including for maintenance where the goods in question are a long-term lease agreement between that Member State and the Russian Federation. |
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Trade restrictions: firearms (amendment to Article 2aa and new Annex XXXV) |
Extension on the prohibition of trade in firearms, to include other arms as listed in new Annex XXXV with any person, entity or body in Russia or for use in Russia. |
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Trade restrictions: (amendment to Article 2d) |
Introduction of a requirement for Member State authorities to exchange information on the enforcement of Articles 2, 2a and 2b with the other Member States and the Commission, including on related infringements and penalties, as well as best practices of national enforcement authorities and the detection and prosecution of unauthorised exports. |
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Transport measures: (new Article 3eb and Article 3ec) |
Prohibition to access EU ports for vessels that engage in ship-to-ship transfers suspected to be in breach of the Russian oil import ban or G7 Coalition price cap. The prohibition is to be in place if a vessel does not notify the competent authority at least 48 hours in advance about a ship-to-ship transfer within the Exclusive Economic Zone of a Member state or within 12 nautical miles from the baseline of that Member State's coast. A further new prohibition to access EU ports for vessels which manipulate or turn off their navigation tracking system at any point of the voyage to a Member State when transporting Russian oil subject to the oil import ban or G7 price cap. Derogations are available in the case of a vessel in need of assistance seeking a place of refuge, or an emergency port call for maritime safety, or for saving a life at sea. Competent authorities may also authorise access for humanitarian purposes. |
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Trade restrictions: iron and steel goods - amendment (amendment to Article 3g) |
Tightening of restrictions on imports of iron and steel goods by requiring importers of sanctioned iron and steel goods that have been processed in a third country to provide evidence of the country of origin of the iron and steel inputs. |
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Trade restrictions: luxury goods - amendment (amendment to Article 3h) |
Introduction of a new prohibition on the provision of technical assistance, brokering services or other services relating to the export of the luxury goods listed in Annex XVIII valued over EUR300 to any person/entity in Russia or for use in Russia. Introduction of a new derogation for vessels falling under CN code 8901 10 00 or 8901 90 00 (or related services), subject to certain conditions. |
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Trade restrictions: revenue-generating goods – new derogation (amendment to Article 3h) |
Introduction of a new derogation for goods falling under CN codes 7007, 8479, 8481, 8487, 8504, 8517, 8525, 8531, 8536, 8537, 8538, 8542, 8543, 8603 if necessary for the operation, maintenance or repair of Budapest metro line 3 cars delivered in 2018, in execution of a guarantee provided by Metrowagonmash prior to 24 June 2023. |
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Trade restrictions: goods contributing to the enhancement of Russian industrial capacities– new exception (amendment to Article 3k) |
Introduction of new exceptions until 25 September 2023 for contracts concluded before 24 June 2023 in respect of:
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Transport measures – Russian trailers and semi-trailers transporting goods (amendment to Article 3l) |
Expansion of the existing prohibition to cover trucks with Russian trailers and semi-trailers from transporting goods to the EU including if those trailers or semi-trailers are hauled by trucks registered in other countries. New exception until 30 June 2023 to the transport of goods that started before 24 June 2023, provided that the trailer or semi-trailer was already in the territory of the Union on 24 June 2023; or needs to transit through the Union in order to be returned to Russia. |
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Maritime transport of Russian oil: exception – amendment (amendment to Article 3m) |
The exception for crude oil falling under CN 2709 00 which is delivered by pipeline from Russia into Member States will cease to apply to Germany and Poland on 23 June 2023. The exemption provided for in relation to the Sakhalin-2 (Сахалин-2) Project, located in Russia, is extended until 31 March 2024 to ensure Japan’s energy security needs. |
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Trade restrictions: Common Military List – amendment (amendment to Article 4) |
Expansion of the existing prohibition in respect of the goods on the Common Military list to include brokering services. |
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Financial restrictions: sale of transferrable securities (amendment to Article 5f) |
Expansion of the existing prohibition to include the sale transferable securities denominated in any currency issued after 6 August 2023 to any Russian national or natural person residing in Russia or any legal person, entity or body established in Russia. |
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Trade restrictions: professional services - services to establish a firewall (amendment of Article 5n) |
A new derogation which permits a Member State authority to authorise the provision of otherwise prohibited services if they are necessary for the establishment of a firewall removing the control by a listed person over the assets of an EU entity. |
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Trade restrictions: Caspian Pipeline Consortium - derogation (new Article 5q) |
New derogation to the prohibitions in Articles 2, 2a, 3f, 3k and 5n to enable the maintenance of the Caspian Pipeline Consortium (CPC) pipeline and associated infrastructure which is necessary for the transport of goods falling under CN 2709 00 originating in Kazakhstan and which are only being loaded in, departing from or transiting through Russia, on certain conditions. |
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Trade restrictions: sensitive dual-use goods and technology – circumvention by third countries (new Article 12f) |
Introduction of a prohibition to on the sale/supply/transfer the goods and technology as listed in a new Annex XXXIII (as yet unpopulated) whether or not originating in the EU, to any natural or legal person, entity or body in the third country specified in that Annex, together with associated technical assistance, brokering services, other services, financing or financial assistance. Annex XXXIII shall only include sensitive dual-use goods and technology, or goods and technology that might contribute to the enhancement of Russia’s military, technological or industrial capacities or to the development of Russia’s defence and security sector, in a way that strengthens its ability to wage war, and whose export to Russia is prohibited under this Regulation and that present a high and continuous risk of being sold, supplied, transferred or exported from third countries to Russia after being sold, supplied, transferred or exported from the EU. Annex XXXIII shall specify, for each item of listed goods or technology, the third countries to which the sale, supply, transfer or export is prohibited. Annex XXXIII shall only include third countries that have been identified by the Council as having systematically and persistently failed to prevent the sale, supply, transfer or export to Russia of goods and technology, as listed in that Annex, exported from the Union, despite the EU's prior outreach and assistance to the country in question. Annex XXXIII has not yet been populated. Decisions to include a third country and targeted goods or technology in the scope of that measure should be based on the inclusion by the Council, acting unanimously, of the relevant country and goods or technology. |
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Derogation: divestment from Russia (amendment to Article 12(b)) |
A new derogation which permits Member State authorities to authorise the sale, supply or transfer of goods and technologies listed in Annexes II, VII, X, XI, XVI, XVIII, XX and XXIII along with associated intellectual property etc until 31 December 2023, where such sale etc is strictly necessary for the divestment from Russia or the wind-down of business activities in Russia. |
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Trade restrictions: entities supporting Russia's military/industrial complex – additions (amendments to Annex IV) |
Addition 87 new entities were added to the list in Annex I of those directly supporting Russia's military and industrial complex in its war of aggression against Ukraine. They are subject to tighter export restrictions for dual-use and advanced technology items. In addition to the Russian and Iranian entities already listed, for the first time this measure also covers entities registered in other jurisdictions, i.e. Armenia, Hong Kong, Syria, the United Arab Emirates and Uzbekistan. |
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Media ban: additions (Article 2f; additions to Annex XV) |
Extension of the existing media prohibitions to five further Russian media outlets (RT Balkan, Oriental Review, Tsargrad, New Eastern Outlook, Katehon). |
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| 5 June 2023 |
Asset freeze – amendment to listing criteria (Amendment to Regulation 269/2014, Article 3(1)(g)) |
Amendment to one of the criteria for the listing of natural or legal persons, entities or bodies, to include leading businesspersons operating in Russia and their immediate family members, or other natural persons, benefitting from them, as well as businesspersons, legal persons, entities or bodies involved in economic sectors providing a substantial source of revenue to the Government of the Russian Federation. |
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(under Regulation (EU) 2020/1998) |
Nine individuals have been added to the EU's list of persons subject to an asset freeze. [These listings are made under the EU's Global Human Rights Sanctions Regime in connection with the ruling by a Moscow court to sentence the opposition politician, democracy activist and outspoken Kremlin critic Vladimir Kara-Murza to 25 years in prison on politically motivated charges based on false allegations started against him in 2022 after he accused the Kremlin of committing war crimes in Ukraine and publicly condemned Russian aggression. For more information, see the press release.] |
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31 May 2023 |
Updated FAQ – internet subdomains |
The EU Commission has updated its Russia Sanctions FAQs by adding an FAQ on whether EU operators are obliged to avoid enabling, facilitating or otherwise contributing to access of internet subdomains and newly-created domains of targeted entities. (See Media FAQ 3). The FAQ confirms that if a domain is blocked, subdomains should be blocked as well. The prohibition also applies to newly created Internet domains that are in substance run or controlled by targeted entities or used to circumvent the prohibition. |
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30 May 2023 |
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Two individuals have been added to the EU's list of persons subject to an asset freeze:
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10 May 2023 |
Updated FAQ – asset freeze and prohibition to make funds and economic resources available |
The EU Commission has updated its Russia Sanctions FAQs by adding an FAQ on whether a non-sanctioned company can request authorisation to use the derogations (on trade in fertilisers) if it does not consider itself to be owned or controlled by a sanctioned person but its counterparts do, and whether that would be an acknowledgement of ownership/control. (See FAQ 41). |
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9 May 2023 |
Upcoming sanctions: EU's 11th package of restrictive measures – press statement by Ursula von der Leyen with President Zelenskyy |
The EU Commission President has announced the details of the EU's upcoming 11th package of restrictive measures, which will focus on circumvention. This will include:
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3 May 2023 |
Guidance Note – Ensuring food security through the implementation of firewalls in cases of EU entities trading in agricultural and food products and controlled by a designated person or entity |
The EU Commission has published a Guidance Note on the implementation of safeguards to insulate EU agricultural trade operations from the control of designated persons or entities, in order to avoid the possibility of global food insecurity as a result of sanctions. Such a framework, referred to as a 'firewall' removes control by the designated person so that trade in agricultural and food products can continue, while the designated person's funds and economic resources remain frozen. |
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26 April 2023 |
Updated FAQ – asset freeze and prohibition to provide funds or economic resources |
The EU Commission has updated its Russia Sanctions FAQs by adding a section on reporting obligations, including on changes to assets in the two weeks before listing on Annex I or prior to designations, specifics on information to be provided and to whom to report on frozen assets. The update also includes a reporting template (see FAQs 35-40). |
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Updated FAQ – Central Bank of Russia |
The EU Commission has updated its Russia Sanctions FAQs by adding a section about the obligation to report immobilised assets belonging to the Central Bank of Russia, including a reporting template (see FAQ 6) and where to report (see FAQ 7). |
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13 April 2023 |
Two entities have been added to EU's list of persons subject to an asset freeze:
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3 April 2023 |
Media restrictions – extensions of existing measures (Article 2f and amendment to Annex XV) |
The EU has confirmed that the existing prohibition on the broadcasting of content has been extended to include:
This will apply from 10 April 2023. (See entries from 25 February 2023 (tenth package) and 16 December 2022 for more information.) |
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31 March 2023 |
Updated FAQ – export-related restrictions |
The EU Commission has updated its Russia sanctions FAQs on exports of controlled goods in transit through Russia (see FAQ 43 for more info). |
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21 March 2023 |
Updated FAQ – crypto-assets |
The EU Commission has updated its Russia sanctions FAQ on crypto-assets. FAQ 2 has been updated to address whether European operators are expected to close the crypto accounts of their Russian customers and return their digital assets, or freeze of these assets. The update states that assets should be returned or be converted into fiat currency or another asset category not subject to sanctions. No freezing of assets is required (see FAQ 2 for more info). |
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Updated FAQ – intellectual property rights |
The EU Commission has made minor clarificatory amendments to its Russia sanctions FAQ on intellectual property rights. (see FAQ 2, 6, 8, 14 and 22 for more info). |
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11 March 2023 |
Updated FAQ – state-owned enterprises |
The EU Commission has updated its Russian sanctions FAQs on state-owned enterprises (see FAQ 13 for more info). |
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10 March 2023 |
EU Parliament Briefing Paper |
The EU Parliament has published a briefing titled "EU sanctions on Russia: Overview, impact and challenges". The briefing includes a summary of the sanctions which have been imposed by the EU on Russia since the invasion. It also sets out a list of the EU Parliament's demands, including:
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9 March 2023 |
REPO Task Force - Joint Statement and Global Advisory |
Shortly following Russia's invasion, Australia, Canada, France, Germany, Italy, Japan, the UK, the US and the EU Commission launched the Russian Elites, Proxies and Oligarchs (REPO) Task Force to coordinate efforts to exert pressure on sanctioned Russian individuals and entities. The REPO Task Force recently published a "Global Advisory on Russian Sanctions Evasion". The REPO Task Force's recommendations for regulated entities include:
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8 March 2023 |
4 Russian police officers and members of the armed forces have been added to EU's list of persons subject to an asset freeze for their involvement in serious human rights violations in Ukraine or against anti-war protesters in Russia:
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7 March 2023 |
EU-Canada Joint Press Release |
The EU and Canada published a joint press release stating that they will increase coordination on sanctions, their enforcement and export control restrictions. The press release further states that Canada has been added as a Partner Country for EU's sanctions regulations against Russia, resulting in better exchange of information and best practices to more effectively enforce existing and future sanctions [see entry dated 25 February below for more information]. |
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2 March 2023 |
G7 Leaders' joint statement following 24 February meeting |
The G7 issued a statement at the one-year mark of Russia's invasion of Ukraine after its call on 24 February 2023. The G7 partners reaffirmed their commitment to strengthening sanctions and imposing new coordinated economic actions against Russia in the days and weeks ahead. This includes the following new measures:
The G7 also reaffirmed the need for an international mechanism to register the damages that Russia has inflicted and for Russia's sovereign assets to remain immobilised in G7 jurisdictions until there is a resolution to the conflict. |
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28 February 2023 |
Updated FAQs |
The EU has updated its "Specialised Financial Messaging Services" FAQs. Please refer to FAQs 1, 2, 3 and 4 for updated FAQs. |
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25 February 2023 EU's "tenth package" of restrictive measures EU Commission press release, European Council press release EU Q&A on the tenth package |
Trade restrictions: transit of dual use items and firearms via Russia (amendment to Articles 2 and 2aa) |
Introduction of a new prohibition on the transit via the territory of Russia of dual-use and technology and firearms, their parts and essential components and ammunition, exported from the EU. Subject to certain pre-existing exceptions. |
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Trade restrictions: aviation and space industry goods or technology (amendment to Article 3c and new Part D of Annex XI) |
Amendment to existing exemptions to restrictions on the export of goods/technology for use in aviation or the space industry (Article 3c – see entry dated 25 February 2022 below):
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Transport restrictions: air travel via Russia – amendment (amendment to Article 3d) |
Aircraft operators of non-scheduled flights between Russia and the EU, operated directly or via a third country, shall notify all relevant information concerning the flight to their competent authorities prior to their operation, and at least 48 hours in advance. |
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Trade restrictions: revenue generating goods – amendment (amendment to Article 3i and new Part C of Annex XXI) |
Amendment to existing exemptions to restrictions on the import of goods which generate significant revenues for Russia (Article 3i – see entry dated 15 July 2022 below):
This new prohibition in respect of the goods in Part C of Annex XXI shall not apply:
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Trade restrictions: enhancement of Russian industrial capacities – amendment (amendment to Article 3k and new Part C of Annex XXIII) |
Amendment to existing exemptions to restrictions on the export of goods which could contribute to the enhancement of Russian industrial capacities (Article 3k – see entry dated 8 April 2022 below):
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Financial restrictions: transferrable securities and money-market instruments issued by the Russian Government – new reporting requirements (amendment to Article 5a) |
All EU natural and legal persons (including banks, the ECB, and CSDs) must report to their national competent authority and the Commission on any assets or reserves belonging to the Central Bank of Russia (or those acting on its behalf, incl. the National Wealth Fund) which they hold or control or are a counterparty to by 12 March 2023 and updated every three months. The Article specifies what information is to be reported. Any unforeseen loss or damage to those assets/reserves must be reported immediately. |
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Financial restrictions: transactions with state-owned entities – new exceptions/derogations (amendment to Article 5aa) |
Amendments to exceptions:
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Ban on Russian nationals holding posts in critical entities (new Article 5o) |
As of 27 March 2023, it shall be prohibited to allow Russian nationals or natural persons residing in Russia to hold any posts in the governing bodies of the owners or operators of critical infrastructures, European critical infrastructures and critical entities. The prohibition shall not apply to nationals of a Member State, a country in the EEA or Switzerland. For the purposes of this prohibition:
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(new Article 5p) |
It shall be prohibited to provide storage capacity in a storage facility, except for the part of liquefied natural gas facilities used for storage, to:
"storage capacity" means any combination of space, injectability and deliverability. "storage facility" means a facility used for the stocking of natural gas and owned and/or operated by a natural gas undertaking, including the part of LNG facilities used for storage but excluding the portion used for production operations, and excluding facilities reserved exclusively for transmission system operators in carrying out their functions. The prohibition above shall not apply to the operations that are strictly necessary for the termination by 27 March 2023 of contracts which are not compliant with this prohibition concluded before 26 February 2023 or of necessary ancillary contracts. National competent authorities can authorise otherwise prohibited activity which is necessary for ensuring critical energy supply within the EU. |
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Professional and business services: derogation - divestment from Russia or wind-down of activities in Russia (amendment to Article 12b) |
Introduction of a new derogation for professional and business services:
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Technical assistance: exception (new Article 12d) |
The prohibitions on providing technical assistance shall not apply to the provision of pilot services to vessels in innocent passage as defined by international law which are necessary for reasons of maritime safety. |
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Trade restrictions: import bans – release of goods from customs (new Article 12e) |
Provisions dealing with when goods subject to import restrictions under EU Russian sanctions can be released from EU customs. These are designed to ensure legal certainty concerning the treatment of imports.
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Trade restrictions: dual use goods / goods contributing to the enhancements of Russia's defence and security sector (Articles 2a and b, amendments to Annex IV and VII) |
96 entities have been added to the list of those who are subject to tighter export restrictions regarding dual-use goods and technology as well as goods and technology which might contribute to the technological enhancement of Russia’s defence and security sector (Annex IV). This includes seven Iranian entities that have been using EU components and providing Russia with military "Shahed" drones to attack civilian infrastructure in Ukraine. The list of goods and technology which might contribute to Russia’s military and technological enhancement, or the development of the defence and security sector (Annex VII) has also been updated to include adding rare-earths and compounds, electronic integrated circuits and thermographic cameras, among others. |
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List of partner countries: update (Amendment to Annex VIII) |
The list of "partner countries" which are applying a set of export control measures substantially equivalent to those set out in the EU Russia Regulation (No. 833/2014) has been expanded to include: Australia, Canada, New Zealand and Norway. The definition is relevant to various derogations and exceptions, and provisions relating to information-sharing. |
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Media restrictions: potential extension of existing measures (Article 2f and amendment to Annex XV) |
The European Council is to consider whether the existing broadcasting prohibition introduced on 16 December 2022 (see entry below) should be expanded to include:
Further legislation will follow if the restrictions are to be so extended. This has now been confirmed – see entry on 3 April 2023 above. |
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Asset freeze: new listings |
87 individuals and 34 entities have been added to the EU's Russian sanctions list. Newly listed individuals include:
Newly listed entities include:
The newly listed entities also include Russian financial institutions and 2 media outlets:
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Asset freeze: specific derogations |
Derogations under which national competent authorities can authorise otherwise prohibited activity by certain entities subject to specific conditions, as follows:
In addition, there a number of amendments to previously granted derogations. |
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Asset freeze: new reporting requirements (Regulation 269/2014, amended Article 8) |
Natural and legal persons must supply the following information to their national competent authority within 2 weeks of acquiring it: 1. information on:
2. information funds and economic resources belonging to or controlled by designated persons/entities which were subject to any dealing/transfer/access/use etc in the 2 weeks before they became designated, including:
Central securities depositories (CSDs) are required to provide the following information to the competent authority of the Member State where they are located, within two weeks of acquiring it and every three months thereafter, and transmit it simultaneously to the Commission:
The obligation to report is ancillary to the effective application of the asset freeze provisions, and is without prejudice to the monetary functions and the principle of independence of the European Central Bank and of the national central banks. All reporting obligations above shall apply from 26 April 2023. |
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24 February 2023 |
Extension of Belarus sanctions |
The EU will prolong for another year restrictive measures imposed on Belarus. The measures will now apply until 28 February 2024. For context, the sanctions against Belarus consist of a ban on travel to the EU and an asset freeze for listed persons and entities (currently 195 individuals and 34 entities). EU persons and entities are also forbidden from making funds available to those listed, either directly or indirectly. Belarus is also subject to targeted economic sanctions, (e.g. restrictions in the financial sector, trade, dual-use goods, technology and telecommunication, economy and transport). |
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23 February 2023 |
The Netherlands published a non-paper on strengthening EU sanctions capacity and countering sanctions circumvention. The proposals include the following:
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EU Sanctions Coordinators Forum- Press release |
The EU held its first Sanctions Coordinators Forum. The event gathered all EU Member States and the U.S, the UK, Japan, Canada, Australia, New Zealand, Norway, Switzerland and Ukraine. The EU also reached out to the United Arab Emirates last week, together with the US Sanctions Coordinator and the UK's Sanctions Directorate, to foster cooperation with third countries. The focus of the meeting was international cooperation in ensuring that sanctions are implemented fully and effectively, notably by analysing circumvention routes and patterns, and potential solutions. |
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20 February 2023 |
EU Council: Foreign Affairs Council - meeting |
The EU Council was joined by Ukraine's Minister of Foreign Affairs, Dmytro Kuleba, to exchange views on the following points during a Foreign Affairs Council:
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15 February 2023 |
Upcoming sanctions: EU's tenth package of restrictive measures - press releases by Ursula von der Leyen and Josep Borell |
The EU Commission President and Vice-President have announced the details of the EU's 10th package of restrictive measures. This package will include the following:
The EU will also organise a Sanctions Coordinator Forum, gathering international partners and Member States to strengthen enforcement efforts. The EU aims, together with its G7 partners, to have significant sanctions in place by 24 February - exactly one year after Russian launched its invasion. |
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14 February 2023 |
Russian oil price cap: Press release- Third country alignment with the EU's price cap on Russian oil products |
A number of third countries have notified the EU that they will align themselves with the EU's decision to introduce two price caps for petroleum products falling under CN code 2710 (see entry dated 4 February 2023 below for more information). These countries are the candidate countries North Macedonia, Montenegro, Albania, Ukraine, and Bosnia and Herzegovina, and the EFTA countries Iceland, Liechtenstein and Norway, members of the European Economic Area. |
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8 February 2023 |
Council of Europe- Press Release & Information Document |
The Council of Europe has suggested creating a register recording evidence and claims for damage, loss or injury to all natural and legal persons concerned, as well as to the State of Ukraine. The register forms part of the EU's initiative to hold Russia accountable for its crimes of aggression. The Council of Europe will rely on the experiences of the United Nations Compensation Commission (UNCC)15 and the United Nations Register of Damage (UNRoD)16 to define the model of the overall compensation mechanism. The Council also explored the possibility of setting-up a special tribunal for the prosecution of the perpetrators of crimes against Ukraine (see entry dated 30 November 2022 below for background information). This initiative is supported by the EU Parliament. Options put forward by the Council to set up the tribunal include:
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7 February 2022 |
Updated Consolidated Guidance |
The EU has updated the following guidance:
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6 February 2023 |
Asset freeze- removal |
The following individual has been removed from the consolidated list and is no longer subject to an asset freeze:
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4 February 2023 |
Following the implementation of the price cap in Russian oil products, the EU has updated:
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EU Press Release- Price Cap on Russian Oil Products Council Decision (CFSP) 2023/252 amending Decision 2014/512/CFSP |
The European Union, the G7 and Price Cap Coalition adopted further price caps for seaborne Russian petroleum products which will come into force from 5 February 2023. This follows the implementation of the price cap for crude oil (see entry dated 3 December 2022 below for more information). Council Decision (CFSP) 2023/252 sets two price levels for Russian petroleum products falling under CN code 2710, namely:
As of mid-March 2023, the review of the price caps should be based on objective data provided by the Commission to the Council every two months. Council Decision (CFSP) 2023/252 also introduces a transitional period of 55 days for vessels carrying petroleum products originating in Russia which are purchased and loaded onto the vessel prior to 5 February 2023 and unloaded at the final port of destination prior to 1 April 2023. |
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Upcoming sanctions: EU's tenth package of restrictive measures |
In a press release relating to the oil price cap, the President of the European Commission, Ursula von der Leyen, stated that the EU is aiming to have its tenth package of sanctions in place by 24 February 2023. |
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30 January 2023 |
Asset Freeze – addition |
One entity has been designated and is now subject to an asset freeze due to its involvement in the development and delivery of Unmanned Aerial Vehicles to Russia:
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27 January 2023 |
Media ban – extension of existing measures |
The broadcasting prohibition introduced on 16 December 2022 (see entry below) will come into force on 1 February 2023 in respect of the following Russian outlets:
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23 January 2023 |
Potential extension of EPPO's powers-EU Parliamentary Response |
The EU Commission is considering whether the powers of the European Public Prosecutor’s Office ("EPPO") should be extended to include breaches of restrictive measures adopted by the EU. At present, the EPPO is responsible for investigating, prosecuting and bringing to judgment crimes against the financial interests of the EU (e.g. fraud, corruption, money laundering and cross-border VAT fraud). An extension of the EPPO's powers would require a unanimous decision of the European Council, followed by an amendment of the EPPO Regulation (Council Regulation (EU) 2017/1939). This follows the EU's decision to add the violation of restrictive measures to the list of EU crimes (see entry dated 28 November 2022 below). |
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17 January 2023 |
Council of Europe conference- Challenges and good practices for the effective implementation of the EU sanctions regime |
Within the framework of the Technical Support Instrument programme, the Council of Europe is currently supporting competent authorities from the Czech Republic, Latvia and Malta, and other Member States in implementing sanctions against Russia. A regional conference was held on 16-17 January 2023 in Prague with representatives of 19 Member States to exchange practices and share experience regarding:
The conclusions of the conference will further enrich the content of the EU's study “Identification of persons holding effective control of a company, establishing firewalls and preventing the sanctions evasion through disinvestment”. |
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11 January 2023 |
Commission Delegated Regulation (EU) 2023/66 of 21 October 2022 amending Regulation (EU) 2021/821 |
The EU has amended the list of dual-use items subject to controls in the EU as part of its annual update:
Other changes are mostly removals, changes of references and editorial changes. |
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10 January 2023 |
EU Statement- Upcoming sanctions against Belarus and Iran |
Following the signature of the Joint Declaration on EU-NATO Cooperation, the EU President, Ursula von der Leyen, announced in a statement that the EU will extend sanctions to those who militarily support Russia's war such as Belarus or Iran. |
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01 January 2023 |
EU Commission work programme 2023 and annexes |
The EU published its 2023 work programme. The programme sets out the list of the most important actions the EU will take in the year ahead. Points relevant to sanctions include:
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21 December 2022 |
Updated FAQs |
The Commission has updated its Russia sanctions FAQs, available here. Please refer to the FAQs below for updates:
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16 December 2022 The EU's "ninth package" of restrictive measures. EU Council press release and EU Commission press release. EU Q&A on this package of restrictive measures can be accessed here. The new/amended Regulations can be accessed here |
Financial restrictions – investment in Russian energy sector – expansion to mining sector (Amendment to Article 3a and new Annex XXX) |
Extension of existing prohibitions targeting new investments in the Russian energy sector by additionally prohibiting new investments in the Russian mining and quarrying sector. It is prohibited to:
"mining and quarrying sector" means a sector covering the location, extraction, management and processing activities relating to non-energy producing materials. This prohibition does not apply to mining and quarrying activities which predominantly relate certain critical raw materials including Aluminium (including bauxite), Chromium, Cobalt, Copper, Iron ore, Mineral fertilisers (including potash and phosphate rock), Molybdenum, Nickel, Palladium, Rhodium, Scandium, Titanium, Vanadium, certain heavy rare earths (dysprosium, erbium, europium, gadolinium, holmium, lutetium, terbium, thulium, ytterbium, yttrium) and certain light rare earths (cerium, lanthanum, neodymium, praseodymium and samarium) – as listed in Annex XXX. |
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Trade restrictions: aviation and space industry goods or technology – amendment to exceptions/derogations (amendment to Article 3c) |
Amendment to existing exemptions to restrictions on trade goods/technology for use in aviation or the space industry (Article 3c – see entry dated 25 February 2022 below):
Introduction of new grounds for authorisation by competent authorities:
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Trade restrictions – iron and steel products – amendment (amendment to Article 3g)
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Addition to the existing prohibitions on trade in Russian iron and steel products (see entries dated 15 March 2022 and 6 October below): From 1 October 2024, the prohibition on the import or purchase of certain iron and steel products processed in a third country incorporating iron and steel products originating in Russia will now include products with CN code 7224 90. Addition to the existing import volume quotas for products with CN code 7224 90 to which the above prohibition will not apply:
Amendment of existing exemption in respect of items listed in Part B of Annex XVII to exclude products with CN code 7224 90. |
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Trade restrictions: various amendments to exemptions to existing restrictions |
Amendments to the exemptions to existing restrictions:
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Trade restrictions: Russian oil and petroleum products – amendments (amendments to Article 3m) |
As from 5 February 2023, it shall be prohibited to:
The Bulgarian competent authority can authorise such activity in specific circumstances. Introduction of specific derogation grounds for the competent authorities of Hungary and Slovakia. |
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Trade restrictions: Russian LNG (amendments to Article 3m) |
Introduction of a requirement for EU persons and entities to report to their competent authority all transactions for:
of natural gas condensates of subheading CN 2709 00 10 from liquefied natural gas production plants, originating in or exported from Russia, including volume information. Based on this information, the European Commission will review measures relating to such products no later than 18 June 2023. |
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Financial restrictions: prohibition on listing by trading venues – amendment (amendments to Article 5(5)) |
Existing prohibition on the listing/providing services by any trading venues in the EU of any transferrable securities by any Russian entity with more than 50 per cent public ownership extended to include a prohibition on admitting those securities to trading as of 29 January 2023. |
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Financial restrictions: transactions with state-owned entities – extended (amendment to Article 5aa) |
From 16 January 2023, the existing prohibitions on transactions with Russian state-owned entities includes a ban on EU nationals from holding any posts in the governing bodies of:
(The ban was previously limited to Annex XIX entities - see entry dated 6 October 2022 for the previous version of the prohibition).
Competent authorities may grant an authorisation to their nationals for holding such posts:
Competent authorities may also authorise, under such conditions as they deem appropriate, transactions which, are strictly necessary for the divestment and withdrawal by 30 June 2023, of the entities mentioned above or their subsidiaries in the Union from a legal person, entity or body established in the Union. In respect of the existing ban on existing prohibitions on transactions with Russian state-owned entities:
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Financial restrictions: bank deposits – reporting requirements (amendment to Article 5g) |
EU credit institutions are required to report to their competent authority by no later than 27 May 2023 a list of deposits exceeding 100.000 EUR held by a legal person, entity or body established outside the EU and whose proprietary rights are directly or indirectly owned for more than 50% by Russian nationals or natural persons residing in Russia. Updates are to be provided every 12 months. |
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Business services: prohibition – new services added (amendment to Article 5n) |
It shall be prohibited to provide market research and public opinion polling services, technical testing and analysis services and advertising services to:
In line with the Central Products Classification as set out in Statistical Office of the United Nations, Statistical Papers, Series M, No 77, CPC prov., 1991:
The ban shall not apply to the provision of services that are strictly necessary for the termination by 16 January 2023 of contracts which are not compliant with this prohibition concluded before 17 December 2022, or of ancillary contracts necessary for the execution of such contracts. Authorisations/derogations available on various grounds. |
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Derogations – divestment from Russia or wind-down of activities in Russia (new Article 12b) |
Introduction of various new grounds for derogations to be granted by Member State competent authorities where such activity is strictly necessary for the divestment from Russia or the wind-down of business activities in Russia, provided certain specified conditions are fulfilled |
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Media ban – extension of existing measures (Article 2f / amendments to Annex XV) |
From 1 February 2023, the existing prohibition on the broadcasting of content will be extended to four Russian outlets:
In line with the Charter of Fundamental Rights, these measures will not prevent those media outlets and their staff from carrying out activities in the EU other than broadcasting, e.g. research and interviews. |
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Trade restrictions: various amendments (amendments to Annex VII, XI, XVII, XXIII, XXV, Annex XXXI and Annex XXXII) |
New export restrictions have been introduced on sensitive dual-use and advanced technologies that contribute to Russia's military capabilities and technological enhancement. This includes drone engines, camouflage gear, additional chemical/biological equipment, riot control agents and additional electronic components found in Russian military systems on the battlefield. Restrictions on key industrial goods used by the Russian military, such as toy/hobby drones, complex generator devices, laptop computers and computing components, printed circuits, radio navigational systems, radio remote control apparatus, cameras and lenses have also been added. |
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Asset freeze: Derogations – release of frozen funds (amendments to Regulation 269/2014) |
Introduction of various grounds for the release of frozen funds by competent authorities:
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The EU's press release is available here. |
Approximately 200 individuals and entities have been added to the EU's list of persons subject to an asset freeze. This includes the Russian armed forces, as well as individual officers and defence industrial companies, members of the State Duma and Federation Council, ministers, Russian proxy authorities in occupied areas of Ukraine and political parties. The newly sanctioned entities include:
The newly sanctioned individuals include:
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12 December 2022 |
4 Iranian individuals and 4 Iranian entities have been added to the list of those subject to restrictive measures for undermining or threatening the territorial integrity, sovereignty and independence of Ukraine. This is due to their role in the development and delivery of drones used by Russia in its war against Ukraine. The entities subject to sanctions are:
The Council has also signalled its intention to impose restrictive measures against a further entity on the same grounds in its press release. |
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9 December 2022 |
Updated FAQs |
The EU has updated its Russia sanctions FAQs on chemicals. Please see the updated guidance under FAQs 6, 9, 11, 13, 15 and 16. |
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8 December 2022 |
Press release- Non-acceptance of Russian travel documents |
The EU adopted a decision not to accept as valid travel documents for obtaining a visa or crossing the borders of the Schengen area Russian travel documents issued in Ukraine and Georgia, or to persons resident in, Russian-occupied regions in Ukraine or breakaway territories in Georgia. |
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3 December 2022 |
Council Decision (CFSP) 2022/2369- Amendment to Decision 2014/512/CFSP Council Regulation (EU) 2022/2367- Amendment to Regulation (EU) No 833/2014 New paragraph 5 of Article 4p of Decision 2014/512/CFSP and new paragraph 5 of Article 3n of Regulation (EU) No 833/2014 New paragraph 6 of Article 4p of Decision 2014/512/CFSP New paragraph 12 of Article 4p of Decision 2014/512/CFSP and new paragraph 11 of Article 3n of Regulation (EU) No 833/2014 |
Amendment to existing restrictions to implement the Russian oil and petroleum products price cap mechanism, set at USD 60 per barrel – see 6 October 2022 entry below. In addition to establishing the price cap, the Council introduced:
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Press Release- Russian oil: EU agrees on level of price cap Council Decision (CFSP) 2022/2369- New Annex XI to Decision 2014/512/CFSP Commission Implementing Regulation (EU) 2022/2368- New Annex XXVIII to Council Regulation (EU) No 833/2014 |
The Council set the oil price cap at USD 60. That is the price per barrel at or below which crude oil from Russia is exempt from the prohibition to provide maritime transport and the prohibition to provide technical assistance, brokering services or financing or financial assistance, related to the maritime transport to third countries. Decision (CFSP) 2022/2369 clarifies:
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2 December 2022 |
SMSG Position Paper- Russian Depositary Receipts |
The Securities and Markets Stakeholder Group (SMSG) of the European Securities and Markets Authority (ESMA) has advised ESMA and the EU Commission to regulate depository receipts (DR) following disruptions to the DR market resulting from sanctions imposed in March 2022 against Russia. The SMSG has also requested guidance and a clear harmonised approach to EU citizens maintaining at least their asset rights (including rights to dividends) in Russian companies. For context, a depositary receipt is a negotiable certificate issued by a bank representing shares in a foreign company traded on a local stock exchange or sold directly to investors. DRs are alternatives to trading directly with the stock exchange in the foreign market. |
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The Commission has published its proposed directive to harmonise criminal offences and penalties for violations of EU sanctions across Member States (please see the entry dated 28 November below for more information). For next steps, the European Parliament and the Council will discuss the proposed directive as part of the ordinary co-legislative procedure. The Commission's Q&A is also available here. The main elements of the proposed directive are summarised below. |
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Proposed definitions of criminal offences (Articles 3 and 4) |
New definitions of the criminal offences related to sanction violations would include:
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Proposed penalties for natural persons (Article 5) |
Depending on the criminal offence committed, natural persons would incur the following penalties:
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Proposed penalties for legal persons (Articles 6 and 7) |
Legal persons would face liability for:
Penalties may include criminal or non-criminal fines, exclusion from entitlement to public benefits or aid, exclusion from access to public funding, including tender procedures, grants and concessions or other penalties, such as:
Firms may also be subject to fines of no less than 5% of the total worldwide turnover of the legal person in the business year preceding the decision (Article 7(3)). |
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30 November 2022 |
Accountability for international crimes- EU Press Release and Statement |
The Commission has put forward two proposals to hold Russia accountable for its crimes against Ukraine, namely:
As Russia does not recognise the jurisdiction of the International Criminal Court, the Commission's intention is that setting up a new court backed by the United Nations would enable Russia's prosecution for crimes of aggression. For next steps, the options above will be presented by the Commission to the Member States for discussion. |
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28 November 2022 |
Harmonisation of sanction penalties across the EU- Proposal for Decision and Press Release |
The Council unanimously adopted a decision to add the violation of restrictive measures to the list of ‘EU crimes’ included in the Treaty on the Functioning of the EU ("TFEU"). The TFEU currently does not provide for the establishment of minimum rules concerning penalties for the violation of EU restrictive measures, since their violation is not yet covered by the areas of crime listed under Article 83(1) TFEU. Different laws across the EU contributes to varying degrees of enforcement depending on the Member State where the infringement is pursued and can lead to forum shopping by offenders. Criminalising the violation of sanctions under Article 83 will ensure a similar degree of sanctions enforcement throughout the EU and will dissuade attempts to violate EU sanctions. For next steps, the Commission will present a proposal for a directive containing minimum rules concerning the definition of criminal offences and penalties for the violation of EU sanctions. The draft directive will then be discussed and adopted by the Council and the Parliament. |
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14 November 2022 |
Asset freeze- Addition |
The EU designated 2 Iranian individuals and 2 Iranian entities for their roles in the development and supply of drones (referred to as "Unmanned Aerial Vehicles") used by Russia in its aggression against Ukraine:
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10 November 2022 |
Updated FAQs- State owned enterprises |
The EU has updated its "State-owned enterprises" FAQs. Please refer to new FAQs 7 and 8 for more information regarding the sanctions on the Russian Maritime Registry of Shipping, and the recognition of an RMRS certification to enter EU waters. |
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9 November 2022 |
Updated FAQs- Asset Freezes |
The EU has updated its "Asset freeze and prohibition to make funds and economic resources available" FAQs. New FAQ 15 clarifies that under no circumstances shall listed shareholders exercise their voting rights in a company or fund whether directly or indirectly. Voting rights must be fully frozen. |
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8 November 2022 |
Updated FAQs- Oil Imports |
The EU has updated its "Oil imports" FAQs. New FAQ 2 clarifies that Russian oil transported and mixed with oil of other origin is subject to the EU's import prohibitions. Mixing through pipelines serving Russian and non-Russian productions for technical reasons should not "generate any avoidable financial flows or indirect benefits in favour of Russian actors for the Russian-origin oil transported via the pipeline, excluding the necessary transportation costs". A quantity of oil corresponding to the non-Russian volume may be allowed into the EU provided that its origin can be clearly demonstrated to the Member States' authorities, for instance through documentation proving the exact volume of oil originating in the non-Russian third country, such as a certificate of origin. |
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26 October 2022 |
Legislative Proposal- Instant Payment Screening |
The EU has proposed amending the Single Euro Payments Area Regulation (EU) No 260/2012 and (EU) 2021/1230 regulating instant credit transfers in euros. The proposed amendments introduce a harmonised approach to avoid the frictions caused by Payment Service Providers ("PSPs") applying divergent screening processes in relation to the requirement to freeze assets and not to make funds or economic resources available to sanctioned persons and entities when executing euro instant payments. Instead of undertaking a transaction-by-transaction sanctions screening, PSPs would be required to verify at least once a day whether any of their customers are designated persons or entities subject to EU sanctions, and in any event, immediately after the entry into force of any new or amended designations. The execution of an instant payment for a sanctioned payer/payee due to a failure to carry out the required verification will result in the PSP being liable for any financial damage to the other PSP (i.e. penalties imposed by the Member State under the EU sanctions regulations). Such requirements would apply 6 months after entry into force of the amendments. Further information is available in the EU's Factsheet and Q&A. |
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24 October 2022 |
Press statement-Outcomes of the first high level meeting on sanctions implementation |
The Commissioner for Financial Services, Financial Stability and Capital Markets Union, Mairead McGuinness, chaired a dedicated high-level meeting with the relevant competent authorities from Member States on sanctions implementation.
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Updated FAQs- Business services |
The EU Commission has updated its Russia sanctions FAQs on business services. The updated FAQs provide further clarification relating to the prohibition of IT consultancy services, architectural and engineering services and legal advisory services. |
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20 October 2022 |
Asset freeze- addition |
The EU designated 3 Iranian individuals and 1 Iranian entity for their roles in the development and supply of drones (referred to as "Unmanned Aerial Vehicles") used by Russia in its aggression against Ukraine:
The EU's press release is available here. |
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18 October 2022 |
Updated FAQs- Russian Maritime Registry of Shipping |
The EU has updated its FAQs on state-owned enterprises to include 5 additional questions in relation to the transaction ban on the Russian Maritime Registry of Shipping. |
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EU response to parliamentary question (asset freeze) |
The EU clarified the following points in response to a parliamentary question:
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14 October 2022 |
3 press releases (available here 1, 2, and 3)- Third country alignment with EU Council Decision |
The EU announced that certain third countries will align their national policies with the EU's decisions forming part of its 8th package of Russia sanctions (namely, EU Council Decisions (CFSP) 2022/1907, 1908 and 1909). |
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12 October 2022 |
Press release- Travel restrictions |
In addition to individual and economic sanctions, the EU also fully suspended the visa facilitation agreement between the EU and Russia (please see the entry dated 9 September 2022 below for more information). On 12 October, the EU ambassadors agreed a mandate for negotiations with the European Parliament on a decision on the non-acceptance of Russian travel documents issued in Ukraine and Georgia. Russian travel documents issued in, or to persons resident in, Russian-occupied regions in Ukraine or breakaway territories in Georgia will not be accepted as valid travel documents for obtaining a visa or crossing the borders of the Schengen area. On the basis of this mandate, the presidency of the Council is ready to start discussions with the European Parliament. |
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10 October 2022 |
Updated FAQs |
The EU has updated its consolidated Russian sanctions FAQs. Additional clarification has been provided on the following topics:
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6 October 2022 The EU's "eighth package" of restrictive measures. EU Council press release and EU Commission press release. EU Q&A on this package of restrictive measures can be accessed here. The new/amended Regulations can be accessed here. |
Trade restrictions: firearms and ammunition (new Article 2aa) |
A prohibition on the sale, supply, transfer or export of firearms and their essential parts and ammunition (as listed in Annex I to Regulation (EU) No 258/2012 – accessible here) to any natural or legal person, entity or body in Russia or for use in Russia. Includes a prohibition on related:
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Trade restrictions: aviation and space industry goods or technology – amendment to exceptions/derogations (amendment to Article 3c) |
Amendment to existing exemptions to restrictions on trade goods/technology for use in aviation or the space industry (Article 3c – see entry dated 25 February 2022 below):
Introduction of a new ground for authorisation by competent authorities: if the activity is deemed necessary for the production of titanium goods required in the aeronautic industry, for which no alternative supply is available. |
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Ships: extension of prohibition on port entry |
Prohibition on access to EU ports and locks (see entries from 8 and 16 April 2022) has been extended to include any vessel certified by the Russian Maritime Register of Shipping. |
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Trade restrictions: iron and steel products (amendment to Article 3g) |
Amendments to the existing restrictions on trade in Russian iron and steel products (listed in Annex XVII – see 15 March entry below), as follows: From 30 September 2023, a prohibition on the import/purchase of the specified iron and steel products processed in a third country incorporating any of the specified iron and steel products originating in Russia, but:
Amendment to the existing exemption:
Introduction of new import volume quotas for products with CN codes 7207 10 or 7207 11 to which the prohibitions will not apply:
- 3 747 905 metric tonnes between 7 October 2022 and 30 September 2023;
- 487 202 metric tonnes between 7 October 2022 and 30 September 2023; Introduction of new grounds for authorisation by competent authorities (incl. civil nuclear facilities, medical applications, environmental radiation monitoring, civil nuclear cooperation). |
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Trade restrictions: goods which generate significant revenues for Russia - amendments (amendment to Article 3i) |
Amendments to existing exemptions:
Introduction of new grounds for authorisation by competent authorities (incl. civil nuclear facilities, medical applications, environmental radiation monitoring, civil nuclear cooperation). |
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Trade restrictions: goods which contribute to the enhancement of Russian industrial capacities – amendment (amendment to Article 3k) |
Introduction of a new exemption: For goods falling under CN codes 2701, 2702, 2703 and 2704 (as listed in Annex XXIII), the prohibitions shall not apply to the execution until 8 January 2023 of contracts concluded before 7 October 2022, or of necessary ancillary contracts. Introduction of new grounds for authorisation by competent authorities (incl. civil nuclear facilities, medical applications, environmental radiation monitoring, civil nuclear cooperation). |
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Trade restrictions: transport of Russian oil and petroleum products – amendment (amendment to Article 3n and new Article 7a) |
The exemption to the existing prohibition (see 3 June entry below) has been extended for petroleum products falling under CN code 2710, such that the prohibition shall not apply to the execution of contracts concluded before 4 June 2022, or of necessary ancillary contracts, until 5 February 2023. Introduction of new exemptions:
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Various changes associated with the price cap oil and petroleum products (to be agreed by the G7). From the date on which the European Council agrees to introduce the price cap, which will be recorded in an amended Annex XXVIII:
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Financial restrictions: transactions with state-owned entities – extensions (amendment to Article 5aa) |
The existing prohibition on engaging in any transactions with the state-owned entities listed in Annex XIX (see 15 March / fourth package below) are extended to include the Russian Maritime Register of Shipping (RMRS), subject to exceptions for:
The EU's recognition of the Russian Maritime Register of Shipping is withdrawn. |
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A new prohibition on EU nationals holding any posts in the governing bodies of: (i) the state owned entities listed Annex XIX; or (ii) any entity owned/controlled or acting on behalf of by those entities, from 22 October 2022. |
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Financial restrictions: crypto-asset services – prohibition |
A complete prohibition on the provision of crypto-asset wallet, account or custody services to Russian nationals or natural persons residing in Russia, or legal persons, entities or bodies established in Russia, regardless of the total value of those crypto-assets (previously up to €10,000 was permitted). |
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Trust services: new exemption (amendment to Article 5m) |
New exemption to the existing prohibition on the provision of trust services (see 8 April / fifth package below):
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Business services: extension of restrictions (amendment to Article 5n) |
A new prohibition on the provision of architectural and engineering services, legal advisory services and IT consultancy services to (i) the Government of Russia; or (ii) legal persons, entities or bodies established in Russia. In line with the Central Products Classification as set out in Statistical Office of the United Nations, Statistical Papers, Series M, No 77, CPC prov., 1991:
Exceptions for:
The exceptions listed at b), c) and d) above also apply to the existing prohibition on the provision of accounting, auditing, including statutory audit, bookkeeping or tax consulting services, or business and management consulting or public relations services – see 3 June / sixth package below. Derogations available for:
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Trade restrictions: extension of existing import /export restrictions |
Expansion of the lists of various categories of goods/technology which are subject to import and export restrictions/prohibitions:
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Asset freeze: new ground for designation - circumvention |
Introduction of a new criteria for designation:
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30 individuals, including individuals that have played a role in the organisation of illegal "referenda", representatives of the defence sector, and well-known persons spreading disinformation about the war. 7 entities:
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Sectoral sanctions - Zaporizhzhia and Kherson regions |
An extension of the geographical scope of the restrictions introduced on 23 February (covering the Donetsk and Luhansk regions) to cover the non-controlled areas of the oblasts of Zaporizhzhia and Kherson. |
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4 October 2022 |
Sanctions in response to the annexation of Crimea and Sevastopol: Member States' competent authorities – updated list |
The EU has amended Annex 1 to Regulation (EU) No 692/2014 (sanctions in response to the illegal annexation of Crimea and Sevastopol) with an updated a list of websites for information on Member States' competent authorities and address for notifications to the Commission (please find the new annex here). These sanctions were extended for a further year in June following Russia's invasion of Ukraine (please see the entry dated 20 June 2022 below). |
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16 September 2022 |
Asset freeze – removal |
3 individuals have been removed from the asset freeze list:
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9 September 2022 |
Council Decision – suspension of visa agreement |
The European Council has issued a decision suspending the application of the Agreement between the European Community and the Russian Federation on the facilitation of the issuance of visas to the citizens of the European Union and the Russian Federation. |
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Asset freeze -removal |
2 individuals have been removed from the asset freeze list4:
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1 September 2022 |
3 individuals:
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4 August 2022 |
2 individuals:
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3 August 2022 |
Notice: Trade restrictions – Russian oil and petroleum products (Article 3m) |
Issuance of a notice to operators regarding imports of Russian crude oil or petroleum products into the EU (i.e. those which are subject to the Article 3m restrictions – see 3 June 2022 entry below). In particular, the notice provides guidance about how the prohibition applies to Russian oil transported together with oil of other origin in mixed form. |
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26 July 2022 |
The European Council has renewed its economic sanctions on Russia for a further six months, until 31 January 2023. |
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21 July 2022 The EU's "seventh package" of restrictive measures (referred to as a "maintenance and alignment" package) EU Q&A on this package of restrictive measures can be accessed here. |
Extension of exemption – agricultural products, oil and petroleum products and pharmaceutical products |
Due to the EU's desire to combat food and energy insecurity, it has extended the exemption from the prohibition to engage in transactions with certain State-owned entities as regards transactions for agricultural products and the supply of oil and petroleum products to third countries. Third countries and their nationals operating outside of the EU are also not prevented from purchasing pharmaceutical or medical products from Russia. |
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Deposits – extension of prohibition |
Expands the prohibition on accepting deposits to include those from legal persons, entities or bodies established in third countries and majority-owned by Russian nationals or natural persons residing inside Russia. The acceptance of deposits for non-prohibited cross-border trade will be subject to prior authorisation by the national competent authorities. |
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Ships – extension of prohibition on port entry |
Prohibition on access to EU ports to vessels registered under the flag of Russia from 16 April 2022 (see entry from 8 April 2022) has been extended to include locks in order to avoid circumvention of sanctions. |
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Trade restrictions – military and technological enhancement |
Extends the list of controlled items, which may contribute to:
thereby reinforcing export controls on dual use and advanced technology (see Annex II). |
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Trade restrictions – Russian gold (new Article 3o) |
Prohibition on the purchase/import/transfer of gold (as listed in Annexes XXVI and XXVII) if it originates in Russia and has been exported from Russia after 22 July 2022, and related technical assistance, brokering services, financing and financial assistance, and services related to the provision, manufacture, maintenance and use of those goods. The prohibition is subject to the following exceptions:
This prohibition applies to jewellery. |
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47 individuals, including those holding leadership positions within the National Guard and Committee on Security and Anti-Corruption; and 9 entities:
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6 individuals, of Syrian nationality, who have recruited individuals to fight in Ukraine alongside Russia:
1 entity: Al-Sayyad Company for Guarding and Protection Services |
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Asset freeze - circumvention |
Prohibits the knowing/intentional participation in activities which aim to circumvent the asset freeze measures. Natural and legal persons on the asset freeze list shall:
Failure to do so will be considered as participation in activities aiming to circumvent the asset freeze measures. The reporting obligation will not apply until 1 January 2023 with regard to funds or economic resources located in a Member State that had a similar reporting obligation prior to 21 July 2022. |
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Asset freeze – supply of information |
Legal persons, entities and bodies are required to:
Cooperate with the competent authority in the verification of such information. |
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Asset freeze – new derogation |
A new derogation from the asset freeze measures – with the authorisation of a Member State, the restrictions shall not apply to specified entities on the asset freeze list with regard to funds or economic resources that are strictly necessary for:
A new general derogation from the asset freeze measures –with the authorisation of a Member State, the restrictions shall not apply to funds or economic resources that are strictly necessary for:
Extends the deadline (see entry from 8 April 2022) from 9 October 2022 to 31 December 2022, or within 6 months from the date of listing in Annex 1, whichever is latest. by which a competent authority may authorise the release of/making available from frozen funds or economic resources belonging to a designated person/entity if
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18 July 2022 |
Asset freeze - Belarus |
One entity, Cham Wings Airlines, has been removed from the asset freeze list. |
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15 July 2022 |
Commission adopts proposal for "maintenance and alignment" package |
The European Commission has adopted a joint proposal for a new package of measures to maintain and strengthen the effectiveness of the EU's six packages of sanctions against Russia. It clarifies a number of provisions to strengthen legal certainty for operators and enforcement by Member States. It also further aligns the EU's sanctions with those of its allies and partners, in particular the G7. The new package will:
It is also proposed that the current EU sanctions should be extended for six months, until the next review in January 2023. For more information, see here. |
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29 June 2022 |
Russian Elites, Proxies, and Oligarchs Task Force Joint Statement |
The Joint Task Force has published a statement on the steps they have been taking to seize assets of those individuals and entities who have been sanctioned in connection with the invasion of Ukraine. See here for the statement and here for the EU's press release |
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24 June 2022 |
Media ban – extension of existing measures |
The extension of the existing prohibition on the broadcasting of content to three further Russian State outlets (Rossiya RTR/RTR Planeta; Rossiya 24/Russia 24 and TV Centre International) which was introduced in the EU's third package (see 3 March below) is to come into force on 25 June 2022. |
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20 June 2022 |
Crimea / Sevastopol: extension of existing sanctions |
Renewal of the sanctions introduced by the EU in response to the illegal annexation of Crimea and Sevastopol by the Russian Federation until 23 June 2023. See also: press release. |
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3 June 2022 |
65 individuals: including military personnel, Government personnel, business people and family members, propagandists and columnists, 18 entities: including military suppliers and contractors, vehicle manufacturers, other suppliers to the Russian Government and Russia's central securities depository. |
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Asset freeze – new derogation |
A new derogation from the asset freeze measures – the restrictions shall not apply to funds or economic resources that are strictly necessary for:
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Penalties for breach of asset freeze measures - amendment |
Amendment to the requirement that Member States shall set out rules on penalties for infringing EU asset freeze measures, to include:
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Media ban – extension of existing measures (Article 2f / Annex XV – amendments) |
Extension of the existing prohibition on the broadcasting of content (see 2 March / third package below) to three further Russian State outlets:
The scope of the measure has been extended to also include a prohibition on the advertising of products or services by the designated media outlets (as listed in Annex XV). This restriction is due to come into force from 25 June 2022, subject to the European Council passing further implementing legislation. |
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Trade restrictions – Russian oil and petroleum products (new Article 3m) |
Prohibition on the purchase/import/transfer of the following crude oil or petroleum products (as listed in Annex XXV) if they originate in Russia or are exported from Russia, and related technical assistance, brokering services, financing or financial assistance.
The prohibition is subject to the following exceptions:
* By way of a temporary derogation, the prohibition at (2) above shall apply to the import and transfer into Czechia, and to the sale to purchasers in Czechia, from 5 December 2023, unless alternative supplies of such products are made available before that date. An exceptional temporary derogation is available for landlocked Member States for seaborne crude oil falling under CN 2709 00 if their supply via pipeline from Russia is interrupted. The competent authorities in Bulgaria and Croatia are able to authorise the execution of contracts concluded before 4 June 2022 until 31 December 2024 and 31 December 2023 (respectively) absolutely (Bulgaria) or in certain circumstances (Croatia). However, those goods cannot be sold on to buyers located in another Member State or in a third country. |
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Trade restrictions – Russian oil/petroleum products - transport services (new Article 3n) |
Prohibition on the provision of technical assistance, brokering services or financing or financial assistance, related to the transport, including through ship-to-ship transfers, to third countries of crude oil or petroleum products (as listed in Annex XXV) which originate in Russia or which have been exported from Russia, subject to the following exceptions:
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Financial restrictions – transactions with state-owned entities – new exceptions (Article 5aa – amendment) |
Amendments to the existing restriction on transactions with specified state-owned entities (Article 5aa / Annex XIX) (see 15 March / fourth package below) to introduce a number of new exceptions for:
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Financial restrictions – accepting deposits – new grounds for authorisation (Article 5c – amendment) |
Introduction of new grounds on which Member State competent authorities can authorise the acceptance of deposits over EUR100,000 (see 25 February/second package below) or the provision of certain crypto asset services valued over EUR10,000 (see 8 April/fifth package below), including:
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Financial restrictions – sale of transferrable securities – amendment to exception (Article 5f – amendment) |
Extension of the exception to the prohibition on the sale of transferrable securities in a Member State currency to nationals/residents of EEA countries and Switzerland. |
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Financial restrictions – SWIFT access (Article 5h / Annex XIV – amendment) |
Extension of the prohibition on the provision of "specialised financial messaging services, which are used to exchange financial data" – i.e. SWIFT – to three further banks from 14 June 2022:
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Various restrictions – amended exceptions/authorisation grounds - Russian natural gas/oil (Various – see right) |
Amendments / additions to the specified exceptions or grounds for authorisation for a number of existing prohibitions to allow for the purchase/import of Russian natural gas and oil, unless such purchase/import prohibited under the new Article 3m/3n prohibitions, as follows:
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(Article 5m – amendments) |
Amendment of the existing prohibition on the provision of trust services (see 8 April/fifth package below) to extend the deadline for the cessation of the provision of prohibited services:
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Business services – prohibition (new Article 5n) |
Prohibition on the provision of accounting, auditing, including statutory audit, bookkeeping or tax consulting services, or business and management consulting or public relations services to:
Exceptions for:
Authorisations available for humanitarian / human rights / civil society purposes. |
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Trade restrictions – extension of existing restrictions |
Expansion of the lists of various categories of goods/technology which are subject to restrictions/prohibitions, as follows:
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Penalties for breach of asset freeze measures – amendment (Article 8 – amendment) |
Amendment to the requirement that Member States shall set out rules on penalties for infringing EU asset freeze measures, to include:
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Belarus: Asset Freeze |
12 individuals: including politicians, business people and family members, media employees and judge. 8 entities: including potash producers, a tobacco company, a vehicle manufacturer and a state television and radio broadcasting company |
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Belarus: Financial restrictions – SWIFT access |
Extension of the prohibition on the provision of "specialised financial messaging services, which are used to exchange financial data" – i.e. SWIFT – to one further bank from 14 June 2022:
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Belarus: Penalties for breach of asset freeze measures – amendment |
Amendment to the requirement that Member States shall set out rules on penalties for infringing EU asset freeze measures, to include:
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24 May 2022 |
Announcement – proposal to freeze and confiscate assets of those violating restrictive measures (See also: Q&A) |
Proposal by the European Commission on freezing and confiscating assets of oligarchs violating restrictive measures and of criminals, as follows:
Making the violation of EU restrictive measures an EU crime The Commission is proposing to add the violation of sanctions to the list of EU crimes. This will allow to set a common basic standard on criminal offences and penalties across the EU. In turn, such common EU rules would make it easier to investigate, prosecute and punish violations of EU sanctions in all Member States alike. Read more in the European Commission's Proposal and Communication. Reinforcing EU rules on asset recovery and confiscation to EU sanctions The Commission is putting forward a proposal for a Directive on asset recovery and confiscation. The proposed rules will also apply to the violation of sanctions, ensuring the effective tracing, freezing, management and confiscation of proceeds derived from the violation of sanctions. Read more in the European Commission's Proposal. |
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8 May 2022 |
Further sanctions announcement - G7 meeting |
A collective commitment from the G7 to taking the following measures:
[The EU has announced measures in respect of each of these in its sixth package of restrictive measures – see below.] |
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4 May 2022 |
Trade restrictions – Russia removed as a destination from the scope of Union general export authorisations |
Amendment to the three general export authorisations granted under Regulation (EU) 2021/821 which permitted exports of dual-use items to Russia in the following situations: (i) re-export of items after repair or replacement in the EU, (ii) export of items for fairs or exhibitions, and (iii) exports of telecommunications equipment. This amendment removes Russia from the destination lists of those three EU general export authorisations in order to prevent Russia from gaining access to critical technologies and dual-use items. Amendment effective on 5 May 2022. |
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21 April 2022 |
2 individuals: Serhiy Vitaliyovich Kurchenko and Yevgeniy Viktorovich Prigozhin |
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13 April 2022 |
Asset freeze – humanitarian exemption/authorisation 5 |
Introduction of a new exception to the asset freeze restrictions: the prohibition on "making funds/economic resources available" to designated persons does not apply to organisations which act as humanitarian partners of the EU provided that the provision of funds/economic resources are required for humanitarian purposes in Ukraine. Relevant Member State authorities can also grant specific of general authorisations for such humanitarian purposes. Deemed authorisation if not granted within 5 working days. [EU FAQs on humanitarian aid published 2 May – accessible here] |
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Trade restrictions: Donetsk and Luhansk regions – humanitarian exemptions |
Amendment to the existing trade restrictions applicable to the Donetsk and Luhansk regions to introduce exceptions for humanitarian purposes to the prohibitions on the goods/technology listed in Annex II (goods and technologies suited for use in the transport; telecommunications; energy; and oil, gas and mineral resources exploration/production). Relevant Member State authorities can also grant specific of general authorisations for such humanitarian purposes. [EU FAQs on humanitarian aid published 2 May – accessible here] |
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Aviation safety: 20 Russian airlines added to EU Air Safety List |
The Commission has updated the EU Air Safety List, which is the list of airlines that are subject to an operating ban or operational restrictions within the European Union, because they do not meet international safety standards. 21 airlines certified in Russia are now included on this list. This reflects serious safety concerns due to Russia's forced re-registration of foreign-owned aircraft, knowingly allowing their operation without valid certificates of airworthiness. This is in breach of international aviation safety standards. |
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8 April 2022 The EU's "fifth package" of restrictive measures EU Q&A on this package of restrictive measures can be accessed here. |
Commissioner for Justice, Didier Reynders urged "all Member States to take all the necessary measures to enforce sanctions and those who have not done so yet to report to the Commission without delay". Member States are still in the process of compiling and sharing the information. Based on reports from more than half of the Member States to the Commission:
The Task Force will continue to meet regularly, the next meeting will take place on 22 April 2022. |
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216 individuals: including Government personnel, oligarchs and family members, business people, propagandists, Putin's daughters, members of the ‘People’s Council’ of Donetsk and ministers of Luhansk 18 entities: including a number of military, engineering and infrastructure companies and four banks:
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Two new derogations from the asset freeze measures - a competent authority may authorise the release of /making available frozen funds or economic resources belonging to:
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Trade restrictions –coal 8 (including amendments to existing exemptions / derogations) |
Prohibition on the purchase/import etc of coal and other solid fossil fuels (Article 3j / as listed in Annex XXII) into the EU if they originate in Russia or are exported from Russia, and associated technical/financial assistance or services. Exemption until 10 August 2022 for contracts concluded before 9 April 2022. Amendments to certain existing restrictions to remove exemptions / derogations for coal:
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Trade restrictions – liquified natural gas (LNG) 9 |
Extension of the existing restrictions on trade in certain goods/technology suited for use in oil refining introduced on 25 February 2022 (see below) (Article 3b / as listed in Annex X) to cover liquefaction of natural gas. |
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Trade restrictions – aviation/space industry 10 |
Extension of the existing restrictions on trade goods/technology for use in aviation or the space industry (Article 3c) to cover jet fuel and fuel additives (as listed in Annex XX) whether or not originating in the EU, to any person/entity in Russia or for use in Russia. [Note: the prohibitions on the provision of insurance/reinsurance and technical/financial assistance etc which apply to goods/technology for use in aviation or the space industry do not appear to have been extended to jet fuel and additives.] New derogation: an authority may authorise activity if it is necessary to ensure lease repayments to an EU individual person/entity which does not fall under any of other EU Russian restrictive measures so long as no economic resources are made available to the Russian counterpart (aside from the return of the aircraft at the end of the lease). [EU FAQs on insurance and reinsurance published 3 May 2022 – accessible here] |
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Ships – prohibition on port entry 11 |
Prohibition on access to EU ports to vessels registered under the flag of Russia from 16 April 2022 (including those which have amended their flag/registration after 24 February 2022). Exemption for emergencies. Authorisation may be granted for the transport/import into the EU of:
[EU FAQs updated on 27 April – accessible here.] |
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Trade restrictions – luxury goods (derogation) 12 |
New derogation to the restrictions on trade in luxury goods (Article 3h) to permit a relevant authority to authorise the return of the transfer or export to Russia of cultural goods which are on loan in the context of formal cultural cooperation with Russia. |
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Trade restrictions – goods generating significant revenue for Russia 13 |
Prohibition on the purchase/import etc of certain specified goods (as listed in Annex XXI) which generate significant revenues for Russia into the EU if they originate in Russia or are exported from Russia, and associated technical/financial assistance or services. Goods include:
Exemption until 10 July 2022 for contracts concluded before 9 April 2022. Other exemptions for certain specified annual quantities of potassium chloride and fertilisers (akin to tariff rate quotas / TRQs). |
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Trade restrictions – enhancement of Russian industrial capacities 14 |
Prohibition on the sale/export etc of certain specified goods (as listed in Annex XXIII) which could contribute in particular to the enhancement of Russian industrial capacities to any person/entity in Russia or for use in Russia, and associated technical/financial assistance or services. Annex XXIII contains a very long and detailed list of the relevant goods (with CN codes). Exemption until 10 July 2022 for contracts concluded before 9 April 2022. Authorisation possible for humanitarian purposes. Exemption for official/diplomatic purposes. |
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Road transport services – access to EU 15 |
Prohibition on any Russian road transport undertaking to transport goods by road in the EU. Exemptions for:
Authorisation may be available for:
[EU FAQs on road transport published on 14 April – accessible here] |
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Trade restrictions – goods in the Common Military List (exemptions) 16 |
Extension of the existing exemptions to the prohibitions relating to goods in the Common Military List to cover the import/export of spare parts and services necessary for the maintenance and safety of existing capabilities within the EU. |
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Financial restrictions – accepting deposits (amendments) 17 |
Extension of the exemption to the prohibition on accepting deposits (see 25 February 2022 below) to the provision of crypto-asset wallet, account or custody services to Russian nationals/residents or entities if the total value of crypto-assets per wallet, account or custody provider exceeds EUR 10,000. [EU FAQs on deposits published on 3 May – accessible here.] |
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Financial restrictions – sale of transferrable securities / banknotes (amendment) 18 |
Existing prohibitions (see 25 February below) on:
are expanded such that they applies to transferrable securities / banknotes denominated in any official currency of a Member State. [As at 11 April 2022, Member States which have not adopted the Euro are: Bulgaria, Croatia, Czechia, Denmark, Hungary, Poland, Romania and Sweden. 19 ] EU FAQs on banknotes published on 20 April– accessible here. |
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Prohibition on the award or continuation of any public or concession contract falling within the scope of the public procurement Directives and certain other Directives to/with:
The prohibition includes subcontractors/suppliers etc where they account for more than 10% of the contract value and where their capacities are being relied on within the meaning of the public procurement Directives. Authorisations may be available for contracts intended for:
Exemption until 10 October 2022 for contracts concluded before 9 April 2022. |
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Financial restrictions – financial support 21 |
Prohibition on the provision of direct or indirect support, including financing and financial assistance or any other benefit under a EU, Euratom or Member State national programme and contracts within the meaning of Regulation (EU, Euratom) 2018/1046, to any legal person, entity or body established in Russia with over 50% public ownership or public control. Exemptions for certain specified purposes/programmes, including: humanitarian; phytosanitary and veterinary; space; civil nuclear; mobility exchange; climate and environmental; and consular/diplomatic. |
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Prohibition on the registration, provision of a registered office, business or administrative address, provision of management services to, a trust or any similar legal arrangement having as a trustor or a beneficiary:
From Exemption for actions which are strictly necessary for the termination by |
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Belarus: Financial restrictions - sale of transferrable securities / banknotes (amendment) 23 |
Existing prohibitions (see 9 March below) on:
are expanded such that they applies to transferrable securities / banknotes denominated in any official currency of a Member State. [As at 11 April 2022, Member States which have not adopted the Euro are: Bulgaria, Croatia, Czechia, Denmark, Hungary, Poland, Romania and Sweden. 24] |
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Belarus: Road transport services – access to EU 25 |
Prohibition on any Belarusian road transport undertaking to transport goods by road in the EU. Exemptions for:
Authorisation may be available for:
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1 April 2022 |
Notice to economic operators, importers and exporters - circumvention |
EU Commission notice: In view of the risk of circumvention of EU sanctions measures, economic operators in the EU are advised to take adequate due diligence measures available in order to prevent circumvention of those measures
The notice states that due diligence measures that exporters and importers are advised to take are, for instance the introduction in import and export contracts of provisions destined to ensure that any imported or exported goods are not covered by the restrictions. The notice warns that operators should take into account that EU customs authorities may carry out more strict controls and may also request conclusive evidence that the concerned goods are not imported from or exported to Russia and Belarus via third countries. [EU FAQs on circumvention and due diligence published 5 April – accessible here] |
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28 March 2022 |
Visa restrictions – "golden passports" / "golden residence permits" |
Commission recommendation regarding investor citizenship schemes (under which the nationality of a Member State, and thereby EU citizenship, is granted in exchange for a pre-determined payment or investment):
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17 March 2022 |
Oligarch Task Force - meeting |
Inaugural ministerial meeting of the Russian Elites, Proxies and Oligarchs Task Force (the "Task Force"). Joint statement confirmed:
Signatories include representatives from: the US, Australia, Canada, France, Germany, Italy, Japan, the UK and the EU. The EU has stated that the European Commission's "Freeze and Seize" Task Force, set up to ensure EU-level coordination to implement sanctions against listed Russian and Belarussian oligarchs, will work alongside the International Task Force. |
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15 March 2022 The EU's "fourth package" of restrictive measures EU Q&A on this package of restrictive measures can be accessed here |
Asset freeze 26 |
15 individuals: oligarchs, senior business-people, propagandists including Roman Abramovich, German Khan, Victor Rashnikov and Alexey Kuzmichev 9 entities associated with ship-building, military, dual-use products and aircraft |
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Trade restrictions – oil exploration / production 27 |
Amendment to the existing restrictions on trade in certain goods suited for oil exploration and production projects in Russia (as listed in Annex II). Prohibition on the sale/supply etc of the Annex II goods to any person/entity in Russia or for use in Russia (incl. its Exclusive Economic Zone and Continental Shelf) and associated technical/financial assistance or services. The prohibition in does not apply:
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Financial restrictions – investments in Russian energy sector 28 |
New prohibition on:
"energy sector" means a sector covering the following activities with the exception of civil nuclear related activities:
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Trade restrictions – iron and steel products 29 |
Prohibition on
The prohibition shall not apply until 17 June 2022 to obligations arising from a contract concluded pre-16 March 2022. |
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Trade restrictions – luxury goods 30 |
Prohibition on the sale/supply/export etc of specified luxury goods to any person/entity in Russia or for use in Russia. Unless otherwise specified, the prohibition only applies to goods valued over EUR 300 (per item). Specified items includes: pure-bred horses, caviar, truffles, various alcoholic drinks, cigars, perfume, leather goods, clothing, precious stones and metals, coins and banknotes, electronics, vehicles, clocks and watches, art, sports equipment [EU FAQs on luxury goods published on 9 April – accessible here] |
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Financial restrictions – transactions with state-owned entities 31 |
Prohibition on engaging in any transaction, directly or indirectly, with 12 specified state-owned entities (as listed in Annex XIX):
The prohibition extends to non-EU persons/entities which are owned more than 50% by the above entities, or a person/entity acting at their behalf etc. The prohibition does not apply:
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Financial restrictions – provision of credit rating services 32 |
Prohibition on the provision of credit rating services or subscription services relating to credit rating activities to any Russian national/resident or entity. Does not apply to EU nationals/residents. [EU FAQs on credit rating published on 28 April – accessible here] |
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11 March 2022 33 |
Trade – revocation of "most favoured nation" status (announced but not yet implemented – G7 leaders' joint statement) |
Denial of Russia's Most-Favoured-Nation (MFN) status relating to key products - the products of Russian companies no longer receive Most-Favoured-Nation treatment in those economies. [Implemented in part (see above): On 15 March 2022, the EU confirmed that it had decided to act not through an increase on import tariffs, but through set of sanctions that comprise bans on the imports or exports of goods on the basis that "this is much quicker and more effective than preparing a completely new tariff schedule from scratch".] |
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Financial restrictions – removal of access to leading multilateral financial institutions (announced but not yet implemented – G7 leaders' joint statement) |
Prohibition on Russia from obtaining financing from the leading multilateral financial institutions, including the International Monetary Fund, the World Bank and the European Bank for Reconstruction and Development. [On 15 March 2022, the EU stated that while Russia's membership of these institutions cannot often be suspended as such, it is working with its international partners to prevent Russia from obtaining financing from these institutions. For example, the EU is working with its partners to make sure that the EBRD suspends Russia and Belarus' access to EBRD finance and expertise.] |
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9 March 2022 The EU's "Compliance package" of restrictive measures |
Financial and investment restrictions - expansion 34 |
Addition of the Russian Maritime Register of Shipping to the list of state-owned enterprises subject to financing limitations – prohibition on all dealings with transferable securities and money-market instruments issued after 12 April 2022 and any new loans/credit (Annex XIII Entities – see 25 February 2022 below). |
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Belarus: Financial restrictions – public/state-owned entities 35 |
A number of financial prohibitions in respect of Belarusian public or state-owned entities, as follows:
Definition of "transferrable securities" includes shares, bonds, other securities, and explicitly includes crypto assets. |
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Belarus: Financial restrictions – accepting deposits 36 |
Prohibition on accepting deposits from Belarusian nationals/residents, or entities established in Belarus in excess of EUR 100,000 per credit institution. Exceptions for:
EU credit institutions are required to provide to the relevant authority a list of deposits exceeding EUR 100 000 held by Belarusian nationals/residents or entities by no later than 27 May 2022. |
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Belarus: Financial restrictions – other 37 |
Prohibition on:
[The restrictions at 2 and 3 were expanded on 8 April 2022 – see above – to apply to securities/banknotes denominated in any official currency of a Member State. EU FAQs on central securities depositories published on 11 April – accessible here.] |
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Belarus: Financial restrictions – SWIFT 38 |
Prohibition from 20 March 2022 on the provision of "specialised financial messaging services, which are used to exchange financial data" – i.e. SWIFT – to three specified banks:
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9 March 2022 The EU's "Compliance package" of restrictive measures |
Asset freeze 39 - individuals |
160 individuals: 13 senior Russian business-people (with a close connection to the Russian Government and/or involved in sectors providing revenue to the Government), F1 racing driver Nikita Dmitrievich Mazepin and 146 members of the Russian Federation Council who ratified the government's actions around the Donetsk and Luhansk regions |
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Financial restrictions – amendments/clarifications 40 |
Clarification that "transferrable securities" includes crypto-assets. Introduction of an exemption to the public financing restriction (see 25 February 2022 below) for financing up to EUR 10 million per project benefiting EU SMEs. |
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Trade restrictions – maritime navigation 41 |
Prohibition on the sale/supply etc of specified maritime navigation goods/technology to any individual/entity in Russia, for use in Russia or for using on board a Russian-flagged vessel, and associated technical or financial assistance, brokering services etc. Exemptions for non-military use, humanitarian purposes, health emergencies, natural disasters etc. [EU FAQs on export restrictions on maritime navigation goods and technology published on 26 April – accessible here] |
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Financial restrictions – Russian National Wealth Fund 42 |
Existing prohibitions on undertaking transactions related to the management of reserves and of assets of the Central Bank of Russia (see 28 February 2022 below) are expanded to include the Russian National Wealth Fund. |
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Financial restrictions – accepting deposits 43 |
Amendment to the exemption to the prohibition on accepting EUR 100,000+ deposits for Russian nationals/entities (see 25 February 2022 below). Prohibition does not apply to nationals of EU Member States, EEA countries or Switzerland. [Prohibition further amended on 8 April 2022] |
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8 March 2022 |
Russian fossil fuels - announcement |
The European Commission has today proposed an outline of a plan to make Europe independent from Russian fossil fuels well before 2030, starting with gas, in light of Russia's invasion of Ukraine. The "REPowerEU" plan is based on two pillars:
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2 March 2022 The EU's "third package" of restrictive measures (part 2) |
Financial restrictions – SWIFT access 44 |
Prohibition from 12 March 2022 on the provision of "specialised financial messaging services, which are used to exchange financial data" – i.e. SWIFT – to seven specified banks:
[Note: Sberbank and Gazprombank have been excluded from these restrictions.] [EU FAQs on SWIFT published on 19 April – accessible here] |
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Financial restrictions – euro denominated banknotes 45 |
Prohibition on the provision of euro denominated banknotes to Russia or to any person/entity in Russia, including the Government and the Central Bank of Russia, or for use in Russia.
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Financial restrictions – Russian Direct Investment Fund 46 |
Prohibition on investment, participation or other contribution to projects co-financed by the Russian Direct Investment Fund. |
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Media ban 47 |
Prohibition on operators broadcasting or facilitate the broadcasting of any content by Russia Today (English, UK, Germany, France, Spanish) and Sputnik by any means (such as cable, satellite, IP-TV, internet service providers, internet video-sharing platforms or applications), as well as the suspension of any licence or authorisation, transmission and distribution arrangement with those entities. [EU FAQs on restrictions on Russian state-owned media published on 23 March – accessible here] |
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Asset freeze 48 |
21 individuals: senior Belarusian ministers/military personnel |
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Trade restrictions – Belarus (in view of the involvement of Belarus in the Russian aggression against Ukraine) |
Prohibition on the sale/supply of:
Exceptions for, for example, humanitarian, non-military, consumer communication, medical or temporary media use. Authorisations possible in certain circumstances. |
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28 February 2022 The EU's "third package" of restrictive measures (part 1) |
Airspace ban 49 |
Prohibition on any aircraft operated by Russian air carriers, or for any Russian registered aircraft, or for any non-Russian-registered aircraft which is owned/chartered/controlled by any Russian person/entity, to land in, take off from or overfly the territory of the EU, except in emergencies. |
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Financial restrictions – Central Bank of Russia 50 |
Prohibition on transactions related to the management of reserves as well as of assets of the Central Bank of Russia, including transactions with any person/entity acting on behalf of, or at the direction of, the Central Bank of Russia. [EU FAQs on the Central Bank of Russia published on 20 April – accessible here] |
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Asset freeze 51 |
25 individuals, including senior business-people (CEOs of Rosneft and Transneft), oligarchs (Alisher Usmanov, Petr Olegovich Aven, Alexander Ponomarenko, Gennady Nikolayevich Timchenko), Government ministers, journalists and senior military personnel. One entity: Gas Industry Insurance Company SOGAZ |
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27 February 2022 |
Trade restrictions – Belarus |
A new package of sanctions aimed at Lukashenko's regime, including:
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26 February 2022 53 |
Visa restrictions – "golden passports" (implemented in part) |
Introduction of measures to limit the sale of citizenship - so called "golden passports" - that let wealthy Russians connected to the Russian government become citizens of Western countries and gain access to their financial systems. As to implementation:
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25 February 2022 The EU's "second package" of restrictive measures |
Trade restrictions – dual-use, military and oil refining 54 |
Ban on the sale/supply, and/or any related technical or financial assistance, in respect of:
There are certain exceptions, including for humanitarian, medical and/or consumer purposes (subject to approvals). |
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Prohibition on the provision of public financing or financial assistance for trade with, or investment in, Russia, subject to certain exceptions:
[Amended on 9 March 2022 – see above.] |
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Financial and investment restrictions (prohibition on new loans / dealing with securities) 56 |
Extended the existing capital markets prohibition, as follows:
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Prohibition on:
Credit institutions are required to provide to the relevant authority in their Member States a list of a list of deposits exceeding 100 000 EUR held by Russian nationals/residents or entities established in Russia, including details of any natural persons who have acquired Member State nationality/residency. [Exemptions amended on 9 March 2022 and 8 April – see above] EU FAQs on the updated restrictions published on 11 April 2022 – accessible here. |
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Additional basis for designation under Council Regulation (EU) No 269/2014 58 |
Added three additional grounds for designation under Annex I of Regulation 269/2014:
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Asset freeze 59 |
98 individuals: including further members of the Russian Duma, members of the Russian Security Council, the Prime Minister of the Russian Federation, other ministers / presidential representatives, those who facilitated Russian military aggression from Belarus (including members of the Belarussian military), Vladimir Putin and Sergey Lavrov. |
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Suspension of certain provisions of the Agreements 61 between the EC/EU and Russia regarding the issuance of visas – essentially, those provisions allowing visa-free travel - including certain provisions in relation to:
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23 February 2022 The EU's "first package" of restrictive measures |
Asset freeze 62 |
22 individuals (incl. senior officials, ministers, military personnel and business persons) Four entities: Internet Research Agency, Bank Rossiya, Vnesheconombank (VEB) and PROMSVYAZBANK (PSB) Derogation: A competent authority may authorise the release of certain frozen funds or economic resources belonging to Bank Rossiya, Vnesheconombank (VEB) and PROMSVYAZBANK (PSB) such funds or economic resources are necessary for the termination by 24 August 2022, of operations, contracts, or other agreements, including correspondent banking relations, concluded with those entities before 23 February 2022. 63 |
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Asset freeze 64 |
336 individual members of Russia State Duma. |
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Financial and investment restrictions (prohibition on new loans / dealing with securities) 65 |
Introduced a new prohibition on dealings with transferable securities and money-market instruments issued after 9 March 2022 by:
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Sectoral sanctions - Donetsk and Luhansk regions 66 |
Ban on the import of goods originating in the Donetsk and Luhansk regions of Ukraine into the EU, and any related financing or insurance in respect of the same. Prohibition on the following in the Donetsk and Luhansk regions:
Ban on the trade of listed goods relating to transport; telecommunications; energy; production of oil, gas and mineral resources, to the Donetsk and Luhansk regions. Prohibition on the provision of tourism services to the Donetsk and Luhansk regions. [EU FAQs on oblasts published on 30 March – accessible here] |
Footnotes
4. Four individuals are listed in this regulation. However, two of the individuals (Viktor Fedorovych Yanukovych and Oleksandr Viktorovych Yanukovych) remain subject to asset freezes under regulation (EU) No 269/2014
5. Council Regulation (EU) 2022/625 of 13 April 2022 amending Regulation (EU) No 269/2014 – new Article 2a
6. Council Implementing Regulation (EU) 2022/581 of 8 April 2022 implementing Regulation (EU) No 269/2014
7. Council Implementing Regulation (EU) 2022/580 of 8 April 2022 implementing Regulation (EU) No 269/2014
8. Council Regulation (EU) 2022/576 of 8 April 2022 amending Regulation (EU) No 833/2014
9. Council Regulation (EU) 2022/576 of 8 April 2022 amending Regulation (EU) No 833/2014
10. Council Regulation (EU) 2022/576 of 8 April 2022 amending Regulation (EU) No 833/2014
11. Council Regulation (EU) 2022/576 of 8 April 2022 amending Regulation (EU) No 833/2014
12. Council Regulation (EU) 2022/576 of 8 April 2022 amending Regulation (EU) No 833/2014
13. Council Regulation (EU) 2022/576 of 8 April 2022 amending Regulation (EU) No 833/2014 – new Article 3i
14. Council Regulation (EU) 2022/576 of 8 April 2022 amending Regulation (EU) No 833/2014 – new Article 3k
15. Council Regulation (EU) 2022/576 of 8 April 2022 amending Regulation (EU) No 833/2014 – new Article 3l
16. Council Regulation (EU) 2022/576 of 8 April 2022 amending Regulation (EU) No 833/2014
17. Council Regulation (EU) 2022/576 of 8 April 2022 amending Regulation (EU) No 833/2014
18. Council Regulation (EU) 2022/576 of 8 April 2022 amending Regulation (EU) No 833/2014
19. https://european-union.europa.eu/institutions-law-budget/euro/countries-using-euro_en
20 Council Regulation (EU) 2022/576 of 8 April 2022 amending Regulation (EU) No 833/2014 – new Article 5k
21. Council Regulation (EU) 2022/576 of 8 April 2022 amending Regulation (EU) No 833/2014 – new Article 5l
22. Council Regulation (EU) 2022/576 of 8 April 2022 amending Regulation (EU) No 833/2014 – new Article 5m
23. COUNCIL REGULATION (EU) 2022/577 of 8 April 2022 amending Regulation (EC) No 765/2006
24. https://european-union.europa.eu/institutions-law-budget/euro/countries-using-euro_en
25. COUNCIL REGULATION (EU) 2022/577 of 8 April 2022 amending Regulation (EC) No 765/2006
26. Council Implementing Regulation (EU) 2022/427 of 15 March 2022 implementing Regulation (EU) No 269/2014
27. Council Regulation (EU) 2022/428 of 15 March 2022 amending Regulation (EU) No 833/2014 - replacement Article 3
28. Council Regulation (EU) 2022/428 of 15 March 2022 amending Regulation (EU) No 833/2014 - replacement Article 3a
29. Council Regulation (EU) 2022/428 of 15 March 2022 amending Regulation (EU) No 833/2014 - new Article 3g
30. Council Regulation (EU) 2022/428 of 15 March 2022 amending Regulation (EU) No 833/2014 - new Article 3h and Annex XVIII
31. Council Regulation (EU) 2022/428 of 15 March 2022 amending Regulation (EU) No 833/2014 - new Article 5aa and Annex XIX
32. Council Regulation (EU) 2022/428 of 15 March 2022 amending Regulation (EU) No 833/2014 - new Article 5j
33.Any measures which have been implemented since their announcement have not been listed here.
34. Council Regulation (EU) 2022/394 of 9 March 2022 amending Regulation (EU) No 833/2014 – amendment to Annex XIII
35. Council Regulation (EU) 2022/398 of 9 March 2022 amending Regulation (EC) No 765/2006
36. Council Regulation (EU) 2022/398 of 9 March 2022 amending Regulation (EC) No 765/2006
37. Council Regulation (EU) 2022/398 of 9 March 2022 amending Regulation (EC) No 765/2006
38. Council Regulation (EU) 2022/398 of 9 March 2022 amending Regulation (EC) No 765/2006
39. Council Implementing Regulation (EU) 2022/396 of 9 March 2022 implementing Regulation (EU) No 269/2014
40. Council Regulation (EU) 2022/394 of 9 March 2022 amending Regulation (EU) No 833/2014 – amendment to Article 2e
41. Council Regulation (EU) 2022/394 of 9 March 2022 amending Regulation (EU) No 833/2014 – new Article 3f
42. Council Regulation (EU) 2022/394 of 9 March 2022 amending Regulation (EU) No 833/2014 – amendment to Article 5a
43. Council Regulation (EU) 2022/394 of 9 March 2022 amending Regulation (EU) No 833/2014 – amendment to Article 5b
44. Council Regulation (EU) 2022/345 of 1 March 2022 amending Regulation (EU) No 833/2014 – new Article 5h
45. Council Regulation (EU) 2022/345 of 1 March 2022 amending Regulation (EU) No 833/2014 – new Article 5i
46. Council Regulation (EU) 2022/345 of 1 March 2022 amending Regulation (EU) No 833/2014 – amendment to Article 2e
47. Council Regulation (EU) 2022/350 of 1 March 2022 amending Regulation (EU) No 833/2014 – new Article 2f
48. Council Implementing Regulation (EU) 2022/353 of 2 March 2022 Implementing Regulation (EU) No 269/2014
49. Council Regulation (EU) 2022/334 of 28 February 2022 amending Council Regulation (EU) No 833/2014 – new Article 3d and e
50. Council Regulation (EU) 2022/334 of 28 February 2022 amending Council Regulation (EU) No 833/2014 – amendments to Article 5a
51. Council Implementing Regulation (EU) 2022/336 of 28 February 2022 implementing Regulation (EU) No 269/2014
52. Any measures which have been implemented since their announcement have not been listed here.
53. Any measures which have been implemented since their announcement have not been listed here.
54. Council Regulation (EU) 2022/328 of 25 February 2022 amending Regulation (EU) No 833/2014 – updated/new Articles 2, 2a-d, 3b-c
55. Council Regulation (EU) 2022/328 of 25 February 2022 amending Regulation (EU) No 833/2014 – new Article 2e
56. Council Regulation (EU) 2022/328 of 25 February 2022 amending Regulation (EU) No 833/2014 – amendments to Article 5
57. Council Regulation (EU) 2022/328 of 25 February 2022 amending Regulation (EU) No 833/2014 – new Articles 5b-g
58. Council Regulation (EU) 2022/330 of 25 February 2022 amending Regulation (EU) No 269/2014
59. Council Implementing Regulation (EU) 2022/332 of 25 February 2022 implementing Regulation (EU) No 269/2014
60. Council Decision (EU) 2022/333 of 25 February 2022
61. Agreement between the European Community and the Russian Federation on the facilitation of the issuance of visas to the citizens of the European Union and the Russian Federation of 1 June 2007, and the Agreement between the European Community and the Russian Federation on readmission
62. Council Implementing Regulation (EU) 2022/260 of 23 February 2022 implementing Regulation (EU) No 269/2014
63. Council Implementing Regulation (EU) 2022/259 of 23 February 2022 implementing Regulation (EU) No 269/2014
64. Council Implementing Regulation (EU) 2022/261 of 23 February 2022 implementing Regulation (EU) No 269/2014
65. Council Regulation (EU) 2022/262 of 23 February 2022 amending Regulation (EU) No 833/2014 (reflecting the adoption of Council Decision (CFSP) 2022/264)
66. Council Regulation (EU) 2022/263 of 23 February 2022
EU Useful Links
- EU Parliament Briefing Paper (March 2023) – useful summary of the EU sanctions imposed on Russia by the EU since the invasion in February 2022, including in relation to the oil price cap, enforcement and the economic impact of sanctions.
- European Commission webpage - sanctions adopted following Russia's military aggression against Ukraine (includes a timeline, overview, FAQs and useful links)
- Consolidated version of FAQs concerning sanctions adopted following Russia's military aggression against Ukraine (individual versions accessible via the webpage above)
- EU Consolidated list of persons, groups and entities subject to EU financial sanctions (various formats available; not Russia-specific)
