EU Adopts New Package of Sanctions Targeting Russia

On 6 October 2022 Council of the European Union adopted an eighth package of sanctions targeting Russia following the recent actions attempted by the Russian Government as part of the special military operation in Ukraine. Besides the extension of the personal sanctions list, EU introduced the following sectoral measures:

Exports

► Firearms. Ban to sell firearms and their essential parts, components, and ammunition to persons in Russia or for the use in Russia. Provision of related services is also banned.
► Aviation. Restrictions related to the export of goods and technology for the use in aviation have been eased. Namely, now restrictions concerning certain goods will not apply to agreements until 6 November 2022 (previously the deadline was 28 March 2022).

Imports

► Steel products. As of 30 September 2023 it becomes prohibited to import or purchase certain listed iron and steel products when processed in a third country incorporating steel products originating in Russia.

• Crypto-asset restrictions. It is now prohibited to provide 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. Previous restriction covered only amounts exceeding EUR 10 000.
• Oil restrictions. New measures provide for a framework allowing to introduce a price cap related to the maritime transport of Russian oil for third countries and further restrictions on the maritime transport of crude oil and petroleum products to third countries. The price cap is yet to be defined.
• Restrictions targeting state-owned companies. New measures prohibit to hold any posts in the governing bodies of listed legal entities established in Russia which are publically owned or controlled.
• Restrictions targeting consultancy, IT, financial and other services. It becomes prohibited to provide, directly or indirectly, accounting, auditing, including statutory audit, bookkeeping or tax consulting services, or business and management consulting or public relations services to the Russian Government and legal persons established in Russia.

It is also prohibited to provide, directly or indirectly, architectural and engineering services, legal advisory services and IT consultancy services to to the Russian Government and legal persons established in Russia.

Exceptions to these bans include:

• Provision of services necessary for termination of said contracts;
• 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
• Provision of services which are strictly necessary to ensure access to judicial, administrative or arbitral proceedings in a Member State,

Provision of services intended for the exclusive use of legal persons, entities or bodies established in Russia that are owned by, or solely or jointly controlled by, a legal person, entity or body which is incorporated or constituted under the law of a Member State, a country member of the European Economic Area, Switzerland or a partner country.

We are actively following the developments related to those issues  and are fully prepared to advise our clients.