9 March 2022

Council Decision (CFSP) 2022/397 and Council Implementing Regulation (EU) 2022/396

• 146 members of the Russian Federation Council as well as 14 individuals supporting and benefitting from the Russian government or providing a substantial source of revenue to it, or associated with listed persons or entities.

15 March 2022

Council Decision (CFSP) 2022/429 and Council Implementing Regulation (EU) 2022/427

• 15 individual oligarchs, including Roman Abramovich and German Khan
• 9 entities active in the aviation, military and dual-use, shipbuilding and machine building sectors:
  • Rosneft Aero (jet fuels)
  • Rosoboronexpor (state intermediary for export-import of military and dual-use products)
  • JSC NPO High Precision Systems (developer and manufacturer of weapons)
  • JSC Kurganmashzavod (major military-industrial complex company)
  • JSC Russian Helicopters (helicopter manufacturing company)
  • PJSC United Aircraft Corporation (manufacturer of civil and military aircraft)
  • JSC United Shipbuilding Corporation (shipbuilding conglomerate)
  • JSC Research and Production Corporation Uralvagonzavod (machine building corporation)
  • JSC Zlznodolsk Shipyard (shipbuilding enterprise)

8 April 2022

Council Decision (CFSP) 2022/582 and Council Implementing Regulation (EU) 2022/581

• 217 individuals, including high-ranking Kremlin officials and oligarchs, such as Moshe Kantor, Boris Rotenberg, and Oleg Deripaska, as well as other prominent business leaders involved in key economic sectors such as energy, finance, media, defence, and arms industry. The EU has also added family members of previously sanctioned individuals.
• 18 sanctioned entities, including prominent banks, such as Otkritie FC Bank (formerly known as NOMOS bank), Novikombank, Sovcombank, and VTB Bank. Other entities sanctioned include Yantar Shipyard (United Shipbuilding Corporation), PJSC United Engine Corporation (Rostec), and JSC Arzamas Machine-Building Plant (Oleg Deripaska's Military Industrial Company).

21 April 2022

Council Decision (CFSP) 2022/660 and Council Implementing Regulation (EU) 2022/658

• Designation of prominent business leaders, including Serhiy Vitaliyovich Kurchenko.

3 June 2022

Council Decision (CFSP) 2022/883 and Council Implementing Regulation (EU) 2022/878

• In the sixth sanctions package, 65 individuals have been designated, including military staff, Colonel Azatbek Omurbekov, Colonel-General Mikhail Mizintsev, and those who participated in the creation of the so-called Committee of Salvation for Peace and Order in March 2022 in Kherson Oblast. These new designations also include politicians, propagandists, leading business leaders, and family members of already sanctioned individuals.
• 18 entities have been added to the list, including a variety of companies supporting, directly or indirectly, the Armed Forces of the Russian Federation and the Government of the Russian Federation, including the National Settlement Depository.

21 July 2022

Council Decision (CFSP) 2022/1272 and Council Implementing Regulation (EU) 2022/1270

• In the seventh sanctions package, 48 individuals have been added to the sanctions list, including the mayor of Moscow, high ranking military officials, leading businesspersons, and nine new entities, including Sberbank, the Russkiy Mir Foundation and the FORSS Group of Companies.

Council Decision (CFSP) 2022/1276 and Council Implementing Regulation (EU) 2022/1274

• The Council also imposed sanctions against six individuals and one entity involved in the recruitment of Syrian mercenaries to fight in Ukraine alongside Russian troops.

Council Decision (CFSP) 2022/1272 and Council Regulation (EU) 2022/1273

• Reporting obligations. In view of the increasing complexity of sanctions evasion schemes, which hamper effective and uniform implementation of EU sanctions, the Council obliged designated persons and entities to report their assets and to cooperate with the competent authority in the verification of such reporting. Natural or legal persons, entities or bodies listed were invited to report before 1 September 2022 or within six weeks from the date of listing, whichever is latest, to the Member States the funds or economic resources they own, hold or control in the EU. The Council has also strengthened the provisions on reporting obligations for Union operators, with a view to preventing the breach or circumvention of asset freezing measures.
• Sberbank. Wind-down period until 22 August 2023 of operations, contracts and other agreements, including correspondent banking relations, concluded with Sberbank before 21 July 2022. In addition, there is a wind-down period until 31 October 2022 for the completion of the ongoing sale and transfer of proprietary rights directly or indirectly owned by Sberbank in any legal person, entity or body established in the Union.
• Agriculture. Competent authorities may authorise the release of certain frozen funds or economic resources belonging to certain entities (e.g., Bank Rossiya, Promsvyazbank, VEB.FR, Otkritie FC Bank, Novikombank, Sovcombank, VTB Bank and Sberbank) if such funds or economic resources are necessary for the purchase, import or transport of agricultural and food products, including wheat and fertilisers.

6 October 2022

Council Decision (CFSP) 2022/1907 and Council Regulation (EU) 2022/1906

• With the eighth sanctions package, the EU targeted those responsible for Russia’s occupation, illegal annexation and sham “referenda” in the occupied territories. It also includes high-ranking and military officials, as well as those who spread disinformation about the war. The eighth sanctions package brings the number of designated individuals to 1262 and the number of entities to 118.

What does this mean? These hundreds of individuals and the entities designated for their involvement in the invasion of Ukraine are now subject to an asset freeze in the EU, which means that all funds and economic resources belonging to, or owned, held or controlled by them are now frozen. The sanctions also cover any natural or legal persons, entities or bodies associated with them. In addition, it is prohibited to make funds or economic resources available, directly or indirectly, to them or for their benefit. Natural persons are also subject to a travel ban in the EU, which prevents them from entering or transiting through EU territories.

Visa policy: Diplomats, Russian officials and business people are no longer able to benefit from visa facilitation provisions.

Restriction on economic relations with the two breakaway regions imposed on 23 February 2022

With Council Decision (CFSP) 2022/266 and Council Regulation (EU) 2022/263 the EU imposed a full set of sanctions on the two non-government controlled areas of the Donetsk and Luhansk oblasts of Ukraine, and in particular: 

• Financial measures: it is prohibited to acquire or extend participation in real estate or entities in the two regions, including acquisition of shares and other securities of a participating nature in entities in the regions. The sanctions also restrict the creation of joint ventures in these territories or with other entities in the regions, the provision of loans, credits or financing to entities in the regions, and the provision of investment services. The restrictions are without prejudice to the execution of obligations arising from contracts concluded before 23 February 2022, provided the competent authorities have been informed at least five working days in advance.
• Import ban: it is prohibited to import goods originating from these two regions, including a prohibition to provide, directly or indirectly, financing or financial assistance, as well as insurance or reinsurance related to these imports. The wind-down period ended on 24 May 2022.
• Tourism: the tourism sector is also impacted as it is prohibited to provide services directly related to tourism activities. There was a wind-down period until 24 August 2022 for contracts concluded before 23 February 2022.
• Export ban: it is prohibited to sell, supply, transfer, or export, or to provide technical assistance, brokering services, training, financing or financial assistance in relation to, the goods listed in Annex II to the Regulation, which are goods suited for the (i) transport, (ii) telecommunication, (iii) energy and (iv) prospecting, exploration and production of oil, gas and mineral resources sectors. It is also prohibited to provide technical assistance or brokering, construction or engineering services directly relating to infrastructure in these sectors, independently of the origin of the goods and technology. There was a wind-down period until 24 August 2022 for contracts concluded before 23 February 2022. 

This prohibition does not apply to public bodies or legal persons, entities or bodies which receive public funding from the Union or Member States, certain organisations and agencies, and certain Member States’ agencies, provided the goods, technology, services and assistance are necessary for exclusively humanitarian purposes in the specified territories.

• Preferential customs origin: The EU also issued a notice to importers advising operators in the EU not to claim preferential treatment for the import into the Union of all goods produced in or exported from the non-government controlled areas of the Donetsk and Luhansk oblasts of Ukraine, since the release of these goods for free circulation would give rise to a customs debt.

• Update eighth sanctions package: the geographical scope of the sanctions has been extended to cover all the non-government controlled areas of Ukraine in the oblasts of Donetsk, Luhansk, Zaporizhzhia and Kherson.

Sectoral restrictions against Russia: the EU has imposed several rounds of sectoral sanctions against Russia with a view to severely impact the Russian economy

Export ban

Council Decision (CFSP) 2022/327 and Council Regulation (EU) 2022/328 

• Technology sector. Export ban against dual-use goods and technology, whether or not originating in the Union, in the sense of Annex I to Regulation (EU) 2021/821 (the ‘Dual-use Regulation’). There was a wind-down period for contracts concluded before 26 February 2022, or ancillary contracts necessary for the execution of such contracts, provided that the authorisation was requested before 1 May 2022. 
• Technology sector. Another export ban targets goods and technology which might contribute to Russia’s military and technological enhancement, or the development of the defence and security sector as listed in Annex VII to the Regulation. The same wind-down period as for the export ban on dual-use goods and technology applies.

Unless otherwise specified, the competent authorities may not grant an authorisation if they have reasonable ground to believe that the end-user might be a military end-user, a natural or legal person, entity or body listed in Annex IV to the Regulation or that the goods might have a military end-use; or when the transaction is intended for the aviation, space or energy sectors.

The sixth EU package expanded the list of goods and technology subject to Annex VII to include 80 chemicals which may be used to produce chemical weapons (Council Decision (CFSP) 2022/884 and Council Regulation (EU) 2022/879). The seventh sanctions package also extended the list of controlled items.

• Update eighth sanctions package: as with the other sanctions package that preceded it, the latest package expanded the list of restricted items which might contribute to the Russian Federation’s military and technological enhancement or to the development of its defence and security sector, by including certain chemical substances, nerve agents and goods which have no practical use other than for capital punishment, torture or other cruel, inhuman or degrading treatment of punishment, or which could be used for those purposes.
• Energy sector. An export ban on goods and technology suited for use in oil refining, as listed in Annex X to the Regulation. The wind-down period ended 27 May 2022. 
• Aviation sector. An export ban on goods and technology suited for use in the aviation or space industry, as listed in Annex XI, and jet fuel and fuel additives, as listed in Annex XX, whether or not originating in the Union, to any natural or legal person, entity or body in Russia or for use in Russia. There is also a prohibition on providing insurance and reinsurance in relation to these items. It is also prohibited to provide technical assistance, brokering services or other services in relation to these goods, unless it is for the exchange of information aimed at establishing technical standards in the framework of the International Civil Aviation Organization and to provide financing and financial assistance. The wind-down period ended 28 March 2022.
• Update eighth sanctions package: new wind-down period until 6 November 2022 for contracts concluded before 7 October 2022, for goods listed in Part B of Annex XI (e.g., hydraulic oils, other lubricating oils, brake linings and pads, new pneumatics tyres of rubber etc.). The wind-down period for Part A items (i.e., Chapter 88) ended in March. An authorization may be granted for Part B items, after the end of the wind-down period, for goods that are necessary for the production of titanium goods required in the aeronautic industry, for which no alternative supply is available.

Council Decision (CFSP) 2022/395 and Council Regulation (EU) 2022/394 

• Maritime sector. Export ban on maritime navigation goods and technology, as listed in Annex XVI to the Regulation, which also includes radio communication technology. 

Council Decision (CFSP) 2022/430 and Council Regulation (EU) 2022/428 

• Energy sector. With its fourth round of sanctions, the EU expanded its already existing sanctions against certain equipment, technology and services related to oil exploration and production in deep waters or in the offshore area north of the Arctic Circle or by hydraulic fracturing, by imposing a complete export ban (these items, listed in Annex II to the Regulation, were subject to prior authorisations). There was a wind-down period until 17 September 2022 for obligations arising from contracts concluded before 16 March 2022, or ancillary contracts necessary for the execution of such contracts, provided that the competent authority has been informed at least five working days in advance. 

However, the sanctions do not apply to the sale, supply, transfer or export of goods or technology, or the provision of technical or financial assistance necessary for the transport of fossil fuels (e.g., coal and natural gas) from or through Russia into the Union, unless prohibited under Article 3m or 3n or for the urgent prevention or mitigation of an event likely to have serious and significant impact on human health and safety or the environment. 

In addition to the export ban, the EU also prohibits new investments in the Russian energy sector, including acquiring new or extending existing participations, granting or being part of any arrangement to grant any new loan or credit, providing financing to any entity operating in the energy sector, or creating joint ventures with legal persons, entities or bodies incorporated or constituted under the law of Russia or any third country and operating in the energy sector in Russia.

• Luxury goods sector. Items such as caviar, truffles, champagne, cigars and perfumes, but also less luxurious items such as railways or tramway parts, or motor vehicle parts and accessories, are subject to an export ban. The list of items concerned can be found in Annex XVIII to the Regulation, and are prohibited insofar as their value exceeds €300 per item, unless otherwise provided by the Regulation.

With the seventh sanctions package, the Council set up a new exemption for items falling under CN 7113. 00. 00 (jewellery) and 7114. 00. 00 (articles of goldsmiths and silversmiths) for personal use of natural persons travelling from the EU or members of their immediate families travelling with them, provided that the items are owned by those individuals and not intended for sale.

Council Decision (CFSP) 2022/578 and Council Regulation (EU) 2022/576

• Goods which contribute to Russia’s military and technological enhancement or the development of its defence and security sector, as listed in Annex XXIII. This includes quantum computers and advanced semiconductors, high-end electronics, software, sensitive machinery, and transportation equipment.

The wind-down period ended on 10 July 2022.

• Update eighth sanctions package: the sanctions package provides for a new wind-down period until 8 January 2023 for contracts concluded before 7 October 2022 for goods falling under CN 2701, 2702, 2703 and 2704 as listed in Annex XXIII. To avoid threats to nuclear safety, the Council also provides for an additional derogation when the goods or technology or the provision of related technical or financial assistance are necessary for the establishment, operation, maintenance, fuel supply and retreatment and safety of civil nuclear capabilities, and the continuation of design, construction and commissioning required for the completion of civil nuclear facilities, the supply of precursor material for the production of material radioisotopes and similar medical applications, or critical technology for environmental radiation monitoring, as well as for civil nuclear cooperation, in particular in the field of research and development.

Council Decision (CFSP) 2022/1909 and Council Regulation (EU) 2022/1904

• Ammunitions. With the eighth sanctions package, it is prohibited to sell, supply, transfer or export, directly or indirectly, firearms, their parts and essential components and ammunitions, as listed in Annex I to Regulation (EU) 258/2012, whether or not originating in the EU.

Import ban

Council Regulation (EU) 2022/428 and Council Decision (CFSP) 2022/430

• Iron and steel. The EU imposed an import ban on iron and steel products, as listed in Annex XVII to the Regulation. It is prohibited to import, purchase or transport, directly or indirectly, iron and steel products originating in Russia, located in Russia or being exported from Russia.

There was a wind-down period until 17 June 2022 for the execution of contracts concluded before 16 March 2022, or ancillary contracts necessary for the execution of such contracts.

• Update eighth sanctions package: it is now also prohibited to import, as from 30 September 2023, directly or indirectly, iron and steel products listed in Annex XVII, when processed in a third country incorporating iron and steel products listed in Annex XVII originating in Russia. With regard to products listed in Annex XVII processed in a third country incorporating steel products originating in Russia of CN codes 7201 11 or 7207 12 10, this prohibition will apply as of 1st April 2024 for CN code 7207 11 and as of 1st October 2024 for CN code 7207 12 10.

The newest package provides for a different wind-down period for goods listed in Part B of Annex XVII. The prohibition does not apply for the execution until 8 January 2023 of contracts concluded before 7 October 2022. However, this wind-down does not apply to goods falling under CN 7207 11 and 7207 12 10:

• For CN 7207 10: transactions are authorized for the import, purchase or transport of 3 747 905 metric tonnes between 7 October 2022 and 30 September 2023; and 3 747 905 metric tonnes between 1 October 2023 and 30 September 2024.
• For CN 7207 11: transaction are authorized for the import, purchase or transport of 487 202 metric tonnes between 7 October 2022 and 30 September 2023; 85 260 metric tonnes between 1 October 2023 and 31 December 2023; and 48 720 metric tonnes between 1 January 2024 and 31 March 2024.

Competent authorities may authorize the purchase, import or transfer of the goods listed in Annex XVII in specific cases, including if the goods are necessary for the establishment, operation, maintenance, fuel supply and retreatment and safety of civil nuclear capabilities.

Council Decision (CFSP) 2022/578 and Council Regulation (EU) 2022/576

• Coal and other products. EU operators are prohibited to purchase, import, or transfer into the EU, directly or indirectly, coal and other products as listed in Annex XXII, if they originate in Russia or are exported from Russia.

The wind-down period ended on 10 August 2022.

• Update eighth sanctions package: the new sanctions package replaced the terms “coal and other fossil fuels” by “coal and other products”.

• Products which generate significant revenues for Russia. This covers, for example, wood, cement, seafood, turbojet, and liquor, as listed in Annex XXI. Since 9 April 2022, it is prohibited to import, purchase, or transport, directly or indirectly, these products if they originate in Russia or are being exported from Russia.

As for coal and other products, the wind-down period ended 10 July 2022.

• Update eighth sanctions package: introduce a new wind-down period for products listed under Part B of Annex XXI, until 8 January 2023 for contracts concluded before 7 October 2022. Part B items includes wood pulp and paper, cigars, nitrites/nitrates, beauty/make up preparations, soap, shaving preparations, polymers of ethylene, polyamides, elements used in the jewellery industry, certain machinery etc.

Council Decision (CFSP) 2022/884 and Council Regulation (EU) 2022/879

• Crude oil and refined petroleum products. The EU restricted the direct or indirect purchase, import, or transfer of crude oil and refined petroleum products, as listed on Annex XXV to the Regulation, which originate in Russia or are exported from Russia, and on the insurance and reinsurance of maritime transport of such goods to third countries. It is also prohibited to provide, directly or indirectly, technical assistance, brokering services, financing, or financial assistance in relation to such imports.

There is a wind-down period until 5 December 2022 or 5 February 2023 for one-off transactions for near-term delivery concluded and executed before these dates, or to the execution of contracts for the purchase, import, or transfer of goods falling under CN 2709 00 and 2710, respectively, concluded before 4 June 2022, provided that those contracts were notified by the relevant Member States to the Commission by 2 June 2022 and that the one-off transaction was notified to the Commission within 10 days of its completion.

Bulgaria, Croatia, and the Czech Republic have obtained some derogatory rules.

• Maritime service ban for crude oil and petroleum products: it is also prohibited to provide, directly or indirectly, 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. The prohibition does not apply to goods which are loaded in, departing from, or transiting through Russia, provided that both the origin and the owner of those goods are non-Russian.

There is a wind-down period until 5 December 2022 for the execution of contracts concluded before 4 June 2022, or ancillary contracts necessary for the execution of such contracts.

• Update eighth sanctions package: the new sanctions package extends the wind-down period until 5 February 2023 for petroleum products falling under CN 2710.

The prohibition to provide technical assistance, brokering services or financing or financial assistance does not apply to the payment of insurance claims after 5 December 2022, for crude oil falling under CN 2709 00, or after 5 February 2023 for petroleum products falling under CN 2710, on the basis of insurance contracts concluded before 4 June 2022 and provided that the insurance coverage has ceased by the relevant date

In addition, it is prohibited to transport, including through ship-to-ship transfers, to third countries, crude oil or petroleum products as of the end of the wind-down periods, for products which originate in Russia or which have been exported from Russia. This prohibition will apply as from the date of entry into force of the Decision amending Annex XI to Decision 2014/512/CFSP. As from the date of every subsequent Decision amending Annex XI, the prohibition will not apply for a period of 90 days, to the products listed in Annex XXV, provided that (i) the transport is based on a contract concluded before that date of entry into force; and (ii) the purchase price per barrel did not exceed the price laid down in Annex XXVIII (the Price Cap Coalition).

The prohibition will not apply, after the end of the wind-down periods, to crude oil and petroleum products, which originate in Russia or which have been exported from Russia, provided that the purchase price per barrels of such products does not exceed the Price Cap Coalition of Annex XXVIII.

The prohibition also does not apply to crude oil or petroleum products where those goods originate in a third country and are only being loaded in, departing from or transiting through Russia, providing that both the origin and the owner of those goods are non-Russian; and for the transport, or technical assistance, brokering services, financing or financial assistance of the products listed in Annex XXIX for the third countries mentioned therein and duration specified in that Annex (concerns only the transport by vessel to Japan, of crude oil falling under CN 2709 00 until 5 June 2023).

This provision does not affect the embargo on Russian crude oil and refined petroleum products. It simply impacts maritime services on trade made above the set cap.

Council Decision (CFSP) 2022/1271 and Council Regulation (EU) 2022/1269

• Gold. It is prohibited to purchase, import or transfer, directly or indirectly, gold, as listed in Annex XXVI, if it originates in Russia or has been exported from Russia into the Union or to any other country after 22 July 2022. The import ban also applies to products processed in a third country incorporating gold products listed in Annex XXVI. It is also prohibited to provide technical assistance, brokering services, financing or financial assistance, or other services in relation to these goods.
• Arms and related material. The eighth sanctions package specifies that the prohibition to import purchase or transport arms and related materiel of all types, including weapons and ammunition, military vehicles and equipment, paramilitary equipment, and spare parts therefor, from Russia by nationals of Member states or using their flag vessels or aircrafts, applies to both direct and indirect import. These items are also subject to an export ban.

Overflight ban

Council Regulation (EU) 2022/334 and Council Decision (CFSP) 2022/335 

• Aviation sector: the EU imposed an overflight ban on the EU airspace and on access to EU airports by Russian carriers of any kind. Concretely, Russian carriers are prohibited to land in, take off from or overfly the territory of the Union, except in the case of an emergency landing or emergency overflight. An exemption can also be granted for humanitarian purposes.

Media ban

Council Decision (CFSP) 2022/351 and Council Regulation (EU) 2022/350

• Suspension, where carried out in the EU or directed at the EU, of the broadcasting activities of Sputnik, RT/Russia Today (RT – Russia Today English; RT – Russia Today UK; RT – Russia Today Germany; RT – Russia Today France; and RT – Russia Today Spanish), Rossiya RTR / RTR Planeta, Rossiya 24 / Russia 24 and TV Centre International.

It is also prohibited to advertise products or services in any content produced or broadcast by these entities.

Vessels and road transport ban

Council Decision (CFSP) 2022/578 and Council Regulation (EU) 2022/576

• Vessel ban. With its fifth sanctions package, the EU further restricted modes of transport between Russia and the EU by prohibiting access after 16 April 2022 to EU ports to any vessel registered under the flag of Russia. The prohibition also applies to vessels having changed their Russian flag or their registration to the flag or register of any other State after 24 February 2022, i.e., between the imposition of the first rounds of sanctions and this fifth sanctions package.

The seventh sanctions package (Council Decision (CFSP) 2022/1271 and Council Regulation (EU) 2022/1269) also prohibited access after 29 July 2022 to locks in the territory of the Union with the exception of access to locks for the purpose of leaving the territory of the Union. In addition, by way of derogation, the competent authorities may authorise vessels that have changed their Russian flag or their registration prior to 16 April 2022 to access ports or locks after having determined that (i) a Russian flag or registration was required by contract; and (ii) the access is necessary for the unloading of goods strictly necessary for the completion of renewable energy projects in the Union.

• Update eighth sanctions package: in addition to vessels registered under the flag of Russia, the prohibition to provide access to ports and locks in the territory of the Union now extends to any vessels certified by the Russian Maritime Register of Shipping as of 8 April 2023.

Member States are also invited to withdraw the authorisations granted to the Russian Maritime Register of Shipping before 5 January 2023. In the meantime, Member States should not allow, or grant a delegation to this entity to perform any of the tasks, which, in accordance with Union rules on maritime safety, are reserved to organisations recognised by the Union. Any statutory certificates issued before 7 October 2022 should be withdrawn and terminated before 8 April 2023.

The eighth sanctions package also provides for additional authorizations. Accordingly, competent authorities may now authorize a vessel to access a port or lock provided that it:

• Has flown the Russian Federation flag under a bareboat charter registration initially effected prior to 24 February 2022;
• Has resumed its rights to fly the flag of the underlying Member State registry before 31 January 2023, and;
• Is not owned, charted, operated or otherwise controlled by a Russian national or any legal person, entity or body incorporated or constituted under the law of the Russian Federation.

• Road transport ban. Similarly, the EU has prohibited any road transport undertaking established in Russia to transport goods by road within the territory of the Union, including in transit.

Financial restrictions

Council Decision (CFSP) 2022/327 and Council Regulation (EU) 2022/328

• Access to capital markets. At the outset of the conflict, the EU first expanded its existing sectoral financial restrictions by further restricting access to capital markets to:
  • Major credit institutions or other major institutions having an explicit mandate to promote the competitiveness of the Russian economy as listed in Annex III to the Regulation (e.g., Rostec).
  • Any major credit institution or any other credit institution having a significant role in supporting the activities of Russia, its government or the Central Bank of Russia, as listed in Annex XII to the Regulation (e.g., Alfa Bank, Bank Otkritie, Bank Rossiya and Promsvyazbank).
  • Legal persons, entities or bodies engaged in the conception, production, sale or export of military equipment or services, as listed in Annex V to the Regulation, or at least 50 per cent of whose revenues originate from the sale or transportation of crude oil or petroleum products, as listed in Annex VI to the Regulation (e.g., Rosneft and Transneft).
  • Legal persons, entities or bodies that are publicly controlled or have over 50 per cent public ownership and in which Russia, its government or the Central Bank has the right to participate in profits or has a substantial economic relationship, as listed in Annex XIII to the Regulation (e.g., Russian Railways and Sovcomflot). 

• The prohibitions also apply to legal persons, entities or bodies that are 50 per cent or more owned by these entities, or that are acting on their behalf or at their direction. These restrictions apply to transferable securities and money-market instruments issued after 12 April 2022.
• Since 12 April 2022 it is also prohibited to list and provide services on trading venues registered or recognised in the Union for the transferable securities of any legal person, entity or body established in Russia and with over 50 per cent ownership, and to make available, or be part of any arrangement to make available, new loans or credit.
• The definition of ‘transferable securities’ has also been amended to include crypto-assets to ensure the proper implementation of the sectoral restrictions in place (Council Decision (CFSP) 2022/395 and Council Regulation (EU) 2022/394). 
• Financial inflows. The EU limits financial inflows from Russia to the EU by:
  • Prohibiting the acceptance of deposits from Russian nationals, natural persons residing in Russia, or legal persons, entities or bodies established in Russia, if the total value of deposits per credit institution exceeds €100,000. Since the seventh sanctions packages, the prohibition also applies to any legal person, entity or body established outside the Union whose proprietary rights are directly or indirectly owned for more than 50 per cent by Russian nationals or natural persons residing in Russia. However, this prohibition does not apply to nationals of a Member State or natural persons having a temporary residence permit in a Member State. It also does not apply to deposits which are necessary for non-prohibited cross-border trade in goods and services between the Union and Russia.
  • In its fifth round of sanctions, the EU extended the prohibition to the provision of crypto-wallets, account, or custody services to Russian nationals and residents or entities established in Russia, if the total value of crypto-assets per wallet, account, or custody provider exceeds €10,000 (Council Decision (CFSP) 2022/884 and Council Regulation (EU) 2022/879).
• Update eighth sanctions package: the new package removes the threshold for the existing prohibition, thereby simply banning the provision of crypto-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 such crypto-assets.
  • Prohibiting EU central securities depositories from providing any services relating to transferable securities issued after 12 April 2022.
  • Prohibiting the selling of transferable securities denominated in any official currency of a Member State issued after 12 April 2022 or units in collective investment undertakings providing exposure to such securities.
  • Prohibiting the provision of public financing or financial assistance for trade with, or investment in, Russia. 

Council Regulation (EU) 2022/334 and Council Decision (CFSP) 2022/335

• Central Bank of Russia. Access to capital markets was also restricted on 23 February 2022 for the Russian Federation, its government, the Central Bank of Russia and any entity acting on behalf of or at the direction of the Central Bank of Russia (Council Decision (CFSP) 2022/264 and Council Regulation (EU) 2022/262). Five days later, on 28 February 2022, the EU prohibited transactions related to the management of the reserves and assets of the Central Bank of Russia, including transactions with any legal persons, entities or bodies acting on its behalf or at its direction. However, the later prohibition does not apply to transactions strictly necessary to ensure the financial stability of the Union as a whole or of the Member State concerned.

Council Decision (CFSP) 2022/346 and Council Regulation (EU) 2022/345

• SWIFT ban. Prohibition (since 12 March 2022) to provide specialised financial messaging services to exchange financial data (SWIFT) to the following seven banks, listed in Annex XIV to the Regulation, or to any legal person, entity or body 50 per cent or more owned by them:
  • Bank Otkritie
  • Novikombank 
  • Promsvyazbank 
  • Rossiya Bank 
  • Sovcombank
  • VNESHECONOMBANK (VEB) 
  • VTB BANK

The SWIFT ban was imposed on banks that had already been the subject to an asset freeze since 23 February 2022. 

In addition to the seven banks above, the sixth EU sanctions package (Council Decision (CFSP) 2022/884 and Council Regulation (EU) 2022/879) extended the prohibition to three additional banks (as of 14 June 2022) and to any legal person, entity, or body 50 per cent or more owned by them:

• Sberbank
• Credit Bank of Moscow
• Joint Stock Company Russian Agricultural Bank, JSC Rosselkhozbank

• Russian Direct Investment Fund. Prohibition to invest or participate in, or otherwise contribute to, projects co-financed by the Russian Direct Investment Fund. There was a wind-down period for investment, participation or contribution due under contracts concluded before 2 March 2022 or ancillary contracts necessary for the execution of such contracts.
• Euro banknotes. Prohibition to sell, supply, transfer, or export banknotes denominated in any official currency of a Member State to Russia, including the government and the Central Bank of Russia, or for use in Russia. 

Council Regulation (EU) 2022/428 and Council Decision (CFSP) 2022/430

• Full economic embargo on certain State-owned enterprises. The fourth sanctions package prohibited to directly or indirectly engage in any transaction with a legal person, entity or body which is publicly controlled or with over 50 per cent public ownership or in which Russia, its government or the Central Bank has the right to participate in profits or a significant economic relationship, as listed in Annex XIX to the Regulation. This also applies to legal persons, entities, or bodies established outside the Union that are 50 per cent or more owned by, or acting on behalf or at the direction of, any entity listed in Annex XIX. 

Entities targeted by this complete ban include Rosneft, Gazprom Neft, and Rostec. 

The wind-down period ended on 15 May 2022.

The prohibition does not apply to transactions necessary for the purchase, import or transport of fossil fuels, in particular coal, oil and natural gas, titanium, aluminium, copper, nickel, palladium and iron ore from or through Russia into the EU, but also, since the seventh sanctions package, countries in the European Economic Area, Switzerland or the Western Balkans.

This prohibition also does not apply to transactions which are necessary for the purchase, import or transport of oil, pharmaceutical, medical, agricultural and food products; for transactions which are strictly necessary to ensure access to judicial, administrative or arbitral proceedings in a Member State, as well as for the recognition or enforcement of a judgment or an arbitration award rendered in a Member State; transactions related to the provision of electronic communication services, data centre services; transactions, including sales, which are necessary for the wind-down by 31 December 2022 of a joint-venture concluded before 16 March 2022 with an entity designated in Annex XIX; transactions related to certain energy projects outside Russia involving entities listed in Annex XIX.

• Update eighth sanctions package: new wind-down period for the execution until 8 January 2023 of contract concluded with legal person, entity or body referred to in Part B of Annex XIX before 7 October 2023. The prohibition does not apply to the reception of payments due by the legal persons, entities or bodies referred to in Part B of Annex XIX pursuant to contract performed before 8 January 2023. This concerns only Russian Maritime Register of Shipping (RMRS), which has been added to the list of State-owned enterprises subject to full economic embargo

The new package also expands the prohibition to engage in any transaction with certain Russian State-owned or controlled legal persons, entities or bodies by including a ban on Union nationals to hold any posts on the governing bodies of those legal persons, entities or bodies as of 22 October 2022.

• Credit rating services. Since 15 April 2022 it is prohibited to provide credit rating services, or access to any subscription services in relation to credit rating activities, to any Russian national or natural person residing in Russia or any legal person, entity or body established in Russia.

Consulting services, public procurement ban, trust

Council Decision (CFSP) 2022/578 and Council Regulation (EU) 2022/576

• Public procurement: it is prohibited to award or continue the execution of any public or concession contract falling within the scope of the public procurement Directives to or with Russian nationals, companies, entities, or bodies established in Russia as well as companies and entities directly or indirectly owned for more than 50 per cent by them and persons bidding or implementing a contract on their behalf; and any person, regardless of their place of establishment or nationality, who implements or intends to implement a contract using Russian or Russian-owned subcontractors, suppliers, or capacity providers for participation above 10 per cent of the contract value.

There is a wind-down period until 10 October 2022 for the execution of contracts concluded before 9 April 2022.

• Financial support to Russian public bodies. With the fifth sanctions package, the EU has strengthened its sanctions by prohibiting the provision of direct or indirect support – including financing and financial assistance or any other benefit under a Union, 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 per cent public ownership or public control.
• Trust: it is prohibited to register or provide a registered office, business, or administrative address as well as management services to a trust or any similar legal arrangement having as a trustor or a beneficiary a Russian national, natural person, legal person, entity, or body residing/established in Russia, as well as companies, entities, or bodies which they own – directly or indirectly – more than 50 per cent of, or any natural or legal person, entity, or body acting on their behalf or at their direction.

It is also prohibited since 5 July 2022 to act as or arrange for another person to act as, a trustee, nominee, shareholder, director, secretary, or a similar position for a trust or similar arrangement as described above.

• Update eighth sanctions package: the new package specifies that the prohibition does not apply when the trustor or beneficiary is a national of a Member State, of a country member of the European Economic Area or of Switzerland, or a natural person having a temporary or permanent residence permit in a Member State, in a country member of the European Economic Area or in Switzerland.

Council Decision (CFSP) 2022/884 and Council Regulation (EU) 2022/879

• Accounting, PR, and consultancy services. The EU prohibits the provision of accounting, auditing, business and management consulting, or public relations services to the Russian government or to legal persons, entities, or bodies established in Russia.

The wind-down period ended on 5 July 2022.

• Update eighth sanctions package: the EU extends the prohibition to architectural and engineering services, legal advisory services and IT consulting services. There is a wind-down period until 8 January 2023 for the provision of services that are strictly necessary for the termination of contracts concluded before 7 October 2022.

“Architectural and engineering services” also covers integrated engineering services, urban planning and landscape architectural services and engineering-related scientific and technical consulting services. “IT consulting services” covers consulting services related to the installation of computer hardware and computer networks, and software implementation services. “Legal advisory services” includes commercial transactions, negotiations, preparation, execution and verification of legal documents.

Regarding legal services, this new measure does not apply to the provision of services that are strictly necessary for the exercise of the right of defence in judicial proceedings and the right to an effective legal remedy; and services that are strictly necessary to ensure access to judicial, administrative or arbitral proceedings, or for the recognition or enforcement of a judgment or an arbitration award rendered in a Member State.

Regarding IT consulting services, this new measures does not apply to the provision of services necessary for software updates for non-military use and for a non-military end-user.

According to the European Commission, the eighth sanctions package responds to Russia’s continued escalation and illegal war against Ukraine, including the illegal annexation of Ukraine territory based on sham “referenda”, mobilising additional troops and issuing open nuclear threats. It includes new export and import restrictions against key products of the Russian economy, including, but not limited to, coking coal, specific electronic components found in Russian weapons, certain chemicals, machinery, plastics, textiles, non-gold jewellery, amongst others. This sanctions package also paves the way for the implementation of the G7 oil price cap, which will help further reduce Russia’s revenues, while keeping global energy markets stable through continued supplies.

In addition to the above, the EU sanctions include a general prohibition on participating, knowingly or intentionally, in activities the object or effect of which is to circumvent prohibitions imposed by the EU, and a prohibition on providing technical assistance, brokering services, financing or financial assistance. With the latest sanctions package, the EU introduced a new listing criterion, which will allow it to sanction persons who facilitate the infringements of the prohibition against circumvention of sanctions (Council Regulation (EU) 2022/1905).

In-depth 2022-089