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Tracker of Sanctions in response to Ukraine Crisis

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.

This tracker was last updated on 16 August 2022.

THE EU 
Date of impositionSanction imposed Summary 
12 August 2022Guidance: Central securities depositoriesPublication of updated EU sanctions guidance: "Frequently asked questions on central securities depositories concerning sanctions adopted following Russia’s military aggression against Ukraine"
4 August 2022Asset freeze

2 individuals:

  • Viktor Fedorovych Yanukovych (oligarch and former president of Ukraine); and
  • Oleksandr Viktorovych Yanukovych (businessman and son of the above).
29 July 2022Guidance: Medicines and medical devicesPublication of EU sanctions guidance: "Frequently asked questions on medicines and medical devices following sanctions adopted in view of Russia’s military aggression against Ukraine".
27 July 2022Guidance: Gold imports Publication of EU sanctions guidance: "Frequently asked questions on gold imports following sanctions adopted in view of Russia’s military aggression against Ukraine
Guidance: AviationPublication of updated EU sanctions guidance: "Frequently asked questions on aviation concerning sanctions adopted following Russia's military aggression against Ukraine".
26 July 2022Renewal of EU economic sanctions The European Council has renewed its economic sanctions on Russia for a further six months, until 31 January 2023.
Guidance: Asset freezesPublication of updated EU sanctions guidance: "Frequently asked questions on asset freezes following sanctions adopted in view of Russia’s military aggression against Ukraine".
Guidance: Reporting obligations under the oil import restrictionsPublication of EU sanctions guidance: "Frequently asked questions on reporting obligations under the oil import restrictions following sanctions adopted in view of Russia’s military aggression against Ukraine".
22 July 2022 "Maintenance and alignment" restrictive measures – questions and answers

Guidance on:

  • Strengthening reporting;
  • The possible effects of EU sanctions on the food sector;
  • The transaction ban with listed entities and state-owned enterprises;
  • Import ban on Russian gold;
  • Export restrictions;
  • Transport-related measures;
  • Financial measures; and
  • Listings of individuals and entities. 
21 July 2022Extension 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.

Depositsextension 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.

Shipsextension of prohibition on port entryProhibition 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.
Trade restrictions military and technological enhancement 

Extends the list of controlled items, which may contribute to:

  • Russia's military and technological enhancement;
  • or the development of its defence and security sector,

thereby reinforcing export controls on dual use and advanced technology (see Annex II).

Trade restrictionsRussian 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:

  • Gold which is necessary for the official purposes of diplomatic missions, consular posts or international organisations in Russia enjoying immunities in accordance with international law;
  • For goods listed in Annex XXVII, for personal use of natural persons travelling to the EU or members of their immediate families travelling with them, owned by those individuals and not intended for sale.
  • The competent authorities may authorise the transfer or import of cultural goods which are on loan in the context of formal cultural cooperation with Russia.

This prohibition applies to jewellery.

Asset freeze

47 individuals, including those holding leadership positions within the National Guard and Committee on Security and Anti-Corruption; and

9 entities:

  • AVLITA Stevedoring Company;
  • Nightwolves MC;
  • The Alexander Gorchakov Public Diplomacy Fund;
  • The Federal Agency for the Commonwealth of Independent States Affairs, Compatriots Living Abroad and International Humanitarian Cooperation (Rossotrudnichestvo);
  • Russkiy Mir Foundation;
  • JSC Research and Production Association "Kvant";
  • Sberbank
  • FORSS Group of Companies; and
  • All-Russia "Young Army" Military Patriotic Social Movement.
Asset freeze

6 individuals, of Syrian nationality, who have recruited individuals to fight in Ukraine alongside Russia:

  • Muhammad Al-Salti;
  • Abu Hani Shammout;
  • Nabeul Al-Abdullah;
  • Simon Al Wakil;
  • Fawaz Mikhail Gerges; and
  • Yasar Hussein Ibrahim

1 entity: Al-Sayyad Company for Guarding and Protection Services 

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:

  • Report before 1 September 2022 or within 6 weeks from the date of listing in Annex I, whichever is latest, funds or economic resources within the jurisdiction of a Member State belonging to, owned, held or controlled by them, to the competent authority of the Member State where those funds or economic resources are located; and
  • Cooperate with the competent authority in any verification of such information.

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.

Asset freeze – supply of information

Legal persons, entities and bodies are required to:

  • Supply immediately any information which would facilitate compliance with the Regulation, such as information on frozen accounts and amounts or information held about funds and economic resources within Union territory

o Belonging to, owned, held or controlled by natural or legal persons, entities or bodies on the asset freeze list; and

o Which have not been treated as frozen by the natural and legal persons, entities and bodies obliged to do so

To the competent authority of the Member State where they are resident or located, and shall transmit such information, directly or through the Member State, to the Commission; and

  • Cooperate with the competent authority in the verification of such information.
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:

  • The termination by 22 August 2023 of operations, contracts, or other agreements including correspondent banking relations concluded with that entity before 21 July 2022;
  • The completion, by 31 October 2022, of an ongoing sale and transfer of proprietary rights in a legal person established in the Union, directly or indirectly owned by that entity;
  • The purchase, import or transport of agricultural and food products, including wheat and fertilisers.

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:

  • The urgent prevention or mitigation of an event likely to have a serious and significant impact on human health and safety or the environment, as long as the proceeds resulting from the release of such economic resources are frozen;

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

  • The funds or economic resources are necessary for the sale and transfer of proprietary rights in an entity established in the EU where those proprietary rights are directly or indirectly owned by a designated individual/entity; and
  • The proceeds of such sale and transfer remain frozen.
19 July 2022Guidance: Agrifood trade and EU sanctionsThe European Commission has published a factsheet to dispel Russian information regarding the disruption of agricultural production and trade in Ukraine and the spike in global food prices.
18 July 2022 Asset freeze - BelarusOne entity, Cham Wings Airlines, has been removed from the asset freeze list.
15 July 2022Commission 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:

  • Introduce a new import ban on Russian gold;
  • Reinforce the dual use and advanced technology export controls; and
  • Strengthen reporting requirements to tighten EU asset freezes.

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.

13 July 2022Guidance: Transit of goods from Russia 

The European Commission has published further guidance to Member States, reiterating Member States' obligation to prevent all possible forms of circumvention of EU restrictive measures.

The guidance confirms that:

  • The transit of sanctioned goods by road with Russian operators is not allowed under the EU measures;
  • No such similar provision exists for rail transport, without prejudice to Member States' obligation to perform effective controls;
  • Member States shall check whether transit volumes remain within the historical averages of the last 3 years, in particular reflecting the real demand for essential goods at the destination, and that there are no unusual flows or trade patterns that could give rise to circumvention;
  • The transit of sanctioned military and dual use goods and technology is fully prohibited in any event – regardless of the mode of transport.

For further information, please see this press release.

Guidance: OblastsPublication of EU sanctions guidance: "Frequently asked questions on Donetsk and Luhansk oblasts concerning sanctions adopted following Russia's military aggression against Ukraine"
Guidance: Road transportPublication of updated EU sanctions guidance: "Frequently asked questions on road transport concerning sanctions adopted following Russia’s military aggression against Ukraine"
8 July 2022Guidance: Deposits Publication of updated EU sanctions guidance: "Frequently asked questions on deposits concerning sanctions adopted following Russia's military aggression against Ukraine"
1 July 2022 Guidance: REACH regulationPublication of EU sanctions guidance: "Frequently asked questions on REACH regulation concerning sanctions adopted following Russia's military aggression against Ukraine"
30 June 2022Guidance: General questionsPublication of updated EU sanctions guidance: "Frequently asked general questions concerning sanctions adopted following Russia's military aggression against Ukraine".
29 June 2022Russian 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

24 June 2022Media ban – extension of existing measures

(Article 2f / Annex XV – amendments)
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.
Guidance: Oil imports Publication of EU sanctions guidance: "Frequently asked questions on oil imports following sanctions adopted in view of Russia’s military aggression against Ukraine".
Guidance: Imports and purchase of goodsPublication of updated EU sanctions guidance: "Frequently asked questions on imports and purchase of goods concerning sanctions adopted following Russia's military aggression against Ukraine"
Guidance: Provision of business servicesPublication of updated EU sanctions guidance: "Frequently asked questions on provision of business services concerning sanctions adopted following Russia’s military aggression against Ukraine
Guidance: Provision of trust servicesPublication of updated EU sanctions guidance: "Frequently asked questions on provision of trust services concerning sanctions adopted following Russia’s military aggression against Ukraine"
23 June 2022Guidance: State-owned enterprises Publication of updated EU sanctions guidance: "Frequently asked questions on the prohibition to engage with certain state-owned enterprises following sanctions adopted in view of Russia’s military aggression against Ukraine".
22 June 2022Guidance: Insurance and reinsurancePublication of updated EU sanctions guidance: "Frequently asked questions on insurance and reinsurance concerning sanctions adopted following Russia's military aggression against Ukraine"
Guidance: Trade in agricultural products from RussiaPublication of EU sanctions guidance: "Frequently asked questions on trade in agricultural products from Russia concerning sanctions adopted following Russia's military aggression against Ukraine"
Guidance: Trade in agricultural products from UkrainePublication of EU sanctions guidance: "Frequently asked questions on trade in agricultural products from Ukraine concerning sanctions adopted following Russia's military aggression against Ukraine"
 20 June 2022Crimea / Sevastopol: extension of existing sanctionsRenewal 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.
 14 June 2022 Guidance: Sale of securitiesPublication of updated EU sanctions guidance: "Frequently asked questions on the sale of securities denominated in the currency of a Member State following sanctions adopted in view of Russia’s military aggression against Ukraine".
 13 June 2022Guidance: Execution of prior contractsPublication of EU sanctions guidance: "Frequently asked questions on execution of prior contracts concerning sanctions adopted following Russia's military aggression against Ukraine"
 9 June 2022 Guidance: Export-related restrictions Publication of EU sanctions guidance: "Frequently asked questions on export-related restrictions concerning sanctions adopted following Russia's military aggression against Ukraine"
 3 June 2022

The EU's "sixth package" of restrictive measures
EU Q&A on this package of restrictive measures can be accessed here.
 Asset Freeze

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.

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:

  • the provision of electronic communication services by EU telecommunication operators,
  • the provision of associated facilities and services necessary for the operation, maintenance and security of such electronic communication services, in Russia, in Ukraine, in the EU, between Russia and the EU, and between Ukraine and the EU, and
  • data centre services in the EU.
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:

  •  that such penalties shall include "as appropriate criminal penalties"; and
  • the inclusion of "appropriate measures of confiscation of the proceeds of such infringements".

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:

  • Rossiya RTR/RTR Planeta
  • Rossiya 24/Russia 24
  • TV Centre International

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.

Trade restrictionsRussian 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.

  • Petroleum oils and oils obtained from bituminous minerals, crude (CN 2709 00)
  • Petroleum oils and oils obtained from bituminous minerals, other than crude; preparations not elsewhere specified or included, containing by weight 70 % or more of petroleum oils or of oils obtained from bituminous minerals, these oils being the basic constituents of the preparations; waste oils (CN 2710)

The prohibition is subject to the following exceptions:

  • until 5 December 2022, to one-off transactions for near-term delivery, concluded and executed before that date, or to the execution of contracts for the purchase, import or transfer of goods falling under CN 2709 00 concluded before 4 June 2022, subject to a notification requirement;
  • until 5 February 2023, to one-off transactions for near-term delivery, concluded and executed before this date, or to the execution of contracts for the purchase, import or transfer of goods falling under CN 2710 concluded before 4 June 2022, subject to a notification requirement;
  • to seaborne crude oil and of petroleum products where those goods originate in a third country and are only transiting through Russia, provided that both the origin and the owner of those goods are non-Russian;
  • to crude oil falling under CN 2709 00 which is delivered by pipeline from Russia into Member States, until the Council decides otherwise. However, (1) such crude oil cannot be sold on to other Member States or third countries, and (2) from 5 February 2023, petroleum products produced from such crude oil cannot be sold on cannot be sold on to other Member States or third countries*.

* 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.

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:

  • the execution until 5 December 2022 of contracts concluded before 4 June 2022; or
  • where such goods originate in a third country and are only transiting through Russia, provided that both the origin and the owner of those goods are non-Russian.

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:

  • The receipt of payments from an Annex XIX entity pursuant to contracts performed before 15 May 2022.
  • Unless prohibited by the new oil/petroleum products restrictions (Article 3m/3n – see above), transactions necessary for the purchase, import or transport of natural gas and oil, including refined petroleum products, titanium, aluminium, copper, nickel, palladium and iron ore from or through Russia into the EU, the EEA, Switzerland, or the Western Balkans.
  • Transactions necessary for the wind-down, by 5 September 2022, of a joint venture or similar legal arrangement concluded before 16 March 2022 with an Annex XIX entity.
  • Transactions necessary for the provision of electronic communications and data centre services and related equipment to an Annex XIX entity.

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:

  • Basic needs
  • Legal fees
  • Fees for the holding/maintenance of frozen funds
  • Necessary extraordinary expenses
  • Official/diplomatic purposes.

Financial restrictionssale 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.

Financial restrictionsSWIFT 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:

  1. Sberbank
  2. Credit Bank of Moscow
  3. Rosselkhozbank

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:

  • The sale/supply etc of certain oil and gas goods/technology (as specified in Annex II) (Article 3)
  • Investments in Russian energy sector (Article 3a)
  • Port access (Article 3ea)
  • Road transport of goods (Article 3l)
  • The award of public or concession contracts (Article 5k)

Trust services – amendments

(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:

  • From 5 July 2022 it will be prohibited to, or arrange for another person to, act as a trustee/nominee/shareholders/director/secretary or similar for a prohibited trust/legal arrangement.
  • Exception for operations which are necessary for the for the termination by 5 July 2022 of contracts which are not compliant with the prohibition concluded before 9 April 2022.
  • Exemption from the prohibition if a trustor/beneficiary is a Member State national or resident.
  • Member State competent authorities can authorise certain services to continue beyond 5 July 2022 in certain circumstances.

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:

a)  the Government of Russia; or

b)  legal persons, entities or bodies established in Russia.

Exceptions for:

  • the provision of services which are necessary for the termination by 5 July 2022 of prohibited contracts concluded before 4 June 2022.
  • necessary legal services ("the exercise of the right of defence in judicial proceedings and the right to the right to an effective legal remedy")
  • services provided to Russian entities which are owned or controlled, solely or jointly, a person/entity incorporated in the EU.

Authorisations available for humanitarian / human rights / civil society purposes.

Trade restrictions – extension of existing restrictions

Expansion of the lists of various categories of goods/technology which are subject to restrictions/prohibitions, as follows:

  • Annex VII ("goods and technology which might contribute to Russia’s military and technological enhancement, or the development of the defence and security sector") – Articles 2a/2b
  • Annex XXI ("goods which generate significant revenues for Russia") – Article 3i

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:

  • that such penalties shall include "as appropriate criminal penalties"; and
  • the inclusion of "appropriate measures of confiscation of the proceeds of such infringements".
 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

 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:

Belinvestbank (Belarusian Bank for Development and Reconstruction)

 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:

  • that such penalties shall include "as appropriate criminal penalties"; and
  • the inclusion of "appropriate measures of confiscation of the proceeds of such infringements".
 2 June 2022 Guidance: Public procurementPublication of updated EU sanctions guidance: "Frequently asked questions on public procurement concerning sanctions adopted following Russia's military aggression against Ukraine".
 1 June 2022Guidance: Credit ratingPublication of updated EU sanctions guidance: "Frequently asked questions on credit rating concerning sanctions adopted following Russia's military aggression against Ukraine
 Guidance: Customs-related mattersPublication of updated EU sanctions guidance: "Frequently asked questions on customs related questions following sanctions adopted in view of Russia’s military aggression against Ukraine".
31 May 2022Guidance: Circumvention and due diligencePublication of updated EU sanctions guidance: "Frequently asked questions on circumvention and due diligence concerning sanctions adopted following Russia's military aggression against Ukraine". 
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:

  1. adding the evasion or violation of EU sanctions to the list of EU crimes; and
  2. new reinforced rules on recovery and confiscation of criminal assets.

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.

Guidance: Prohibition to access to EU portsPublication of updated EU sanctions guidance: "Frequently asked questions on prohibition to access EU ports concerning sanctions adopted following Russia's military aggression against Ukraine".
8 May 2022Further sanctions announcement - G7 meeting

A collective commitment from the G7 to taking the following measures:

  • Phasing out dependency on Russian energy, including by phasing out or banning the import of Russian oil;
  • Prohibiting or otherwise preventing the provision of key services to Russia;
  • Continuing to take action against Russian banks;
  • Continuing efforts to fight off the Russian regime's attempts to spread propaganda; and
  • Continuing and elevating measures against the financial elites and family members who support President Putin in his war, including imposing sanctions on additional individuals.

[The EU has announced measures in respect of each of these in its sixth package of restrictive measures – see below.]

4 May 2022
Guidance: TradingPublication of updated EU sanctions guidance: "Frequently asked questions on trading following sanctions adopted in view of Russia’s military aggression against Ukraine"
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.

Guidance: Aviation/space industryPublication of EU sanctions guidance: "Frequently asked questions on insurance and reinsurance concerning sanctions adopted following Russia's military aggression against Ukraine"
2 May 2022Guidance: Luxury goodsPublication of EU sanctions guidance: "Frequently asked questions on luxury goods concerning sanctions adopted following Russia's military aggression against Ukraine"
27 April 2022Guidance: Prohibition on access to EU portsPublication of EU sanctions guidance: "Frequently asked questions on the prohibition to access to EU ports concerning sanctions adopted following Russia’s military aggression against Ukraine and Belarus' involvement in it".
26 April 2022Guidance: Export restrictions on maritime navigation goods and technologyPublication of updated EU sanctions guidance: "Frequently asked questions on export restrictions on maritime navigation goods and technology concerning sanctions adopted following Russia’s military aggression against Ukraine"
21 April 2022Asset Freeze2 individuals: Serhiy Vitaliyovich Kurchenko and Yevgeniy Viktorovich Prigozhin
20 April 2022 Guidance: BanknotesPublication of updated EU sanctions guidance: "Frequently asked questions on banknotes concerning sanctions adopted following Russia’s military aggression against Ukraine"
Guidance: Central Bank of RussiaPublication of updated EU sanctions guidance: "Frequently asked questions on Central Bank of Russia concerning sanctions adopted following Russia’s military aggression against Ukraine"
19 April 2022Guidance: SWIFTPublication of updated EU sanctions guidance: "Frequently asked questions on SWIFT concerning sanctions adopted following Russia’s military aggression against Ukraine"
13 April 2022

Asset freezehumanitarian

exemption/authorisation 4

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]

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]

Guidance: Technical assistance

Publication of updated EU sanctions guidance: "Frequently asked questions on technical assistance concerning sanctions adopted following Russia’s military aggression against Ukraine and Belarus' involvement in it".

11 April 2022 Guidance: Crypto assets

Publication of EU sanctions guidance: "Frequently asked questions on crypto-assets concerning sanctions adopted following Russia’s military aggression against Ukraine".

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.

8 April 2022

The EU's "fifth package" of restrictive measures

EU Q&A on this package of restrictive measures can be accessed here.

Meeting of the EU's "Freeze and Seize Task Force"

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:

  • €29.5 billion worth of assets have been frozen, including boats, helicopters, real estate and artwork, worth almost €6.7 billion.
  • €196 billion of transactions have been blocked.

The Task Force will continue to meet regularly, the next meeting will take place on 22 April 2022.

Asset Freeze5

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:

  • Otkritie FC Bank
  • Novikombank
  • Sovcombank
  • VTB Bank
Derogation from asset freeze measures 6

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:

  • Otkritie Bank, Novikombank, Novcombank and VTB Bank if 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.
  • a designated person/entity if: (i) the funds or economic resources are necessary for the sale and transfer by 9 October 2022 of proprietary rights in an entity established in the EU where those proprietary rights are directly or indirectly owned by a designated individual/entity; and (ii) the proceeds of such sale and transfer remain frozen.

Trade restrictionscoal 7

(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:

  • Existing exemption to the restrictions on trade in certain goods/technology suited for oil exploration and production projects in Russia (Article 3 / as listed in Annex II) narrowed to remove reference to the transport of coal.
  • Existing derogation from the restrictions on investments in Russian energy sector introduced on 15 March 2022 (see below) (Article 3a) narrowed to remove reference to the transport of coal.
  • As regards the existing restriction on transactions with specified state-owned entities (Article 5aa / Annex XIX):

- existing general exemption narrowed to remove reference to transactions relating to the import/transport of coal

- new exemption introduced to exempt until 10 August 2022 transactions relating to the import/transport coal and other solid fossil fuels (as listed in Annex XXII).

Trade restrictions – liquified natural gas (LNG) 8Extension 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.
Trade restrictions – aviation/space industry 9

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]

Ships – prohibition on port entry 10

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:

  • natural gas and oil, including refined petroleum products, titanium, aluminium, copper, nickel, palladium and iron ore, as well as certain chemical and iron products (as listed in Annex XXIV)
  • pharmaceutical, medical, agricultural and food products, including wheat and fertilisers (provided not otherwise prohibited)
  • nuclear fuel and other goods strictly necessary for the functioning of civil nuclear capabilities
  • coal and other solid fossil fuels (as listed in Annex XXII) until 10 August 2022

[EU FAQs updated on 27 April – accessible here.]

Trade restrictions – luxury goods (derogation) 11New 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.
Trade restrictions – goods generating significant revenue for Russia 12

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:

  • Crustaceans and caviar
  • Cement
  • Various chemicals
  • Fertilisers
  • Tyres, wood, paper and glass products
  • Certain metals, incl. silver, aluminium and lead
  • Turbines, ships and other craft

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).

Trade restrictions – enhancement of Russian industrial capacities 13

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.

Road transport services – access to EU 14

Prohibition on any Russian road transport undertaking to transport goods by road in the EU.

Exemptions for:

  • mail as a universal service
  • goods in transit though the EU between the Kaliningrad Oblast and Russia (provided not otherwise prohibited)
  • until 16 April 2022 to the transport of goods that started before 9 April 2022, provided that the vehicle of the road transport undertaking: (a) was already in the EU on 9 April 2022, or (b) needs to transit through the EU to return to Russia

Authorisation may be available for:

  • the transport into the EU of natural gas and oil, including refined petroleum products, titanium, aluminium, copper, nickel, palladium and iron ore
  • the transport of pharmaceutical, medical, agricultural and food products, including wheat and fertilisers (provided not otherwise prohibited)
  • humanitarian purposes
  • diplomatic/consular purposes
  • the transfer or export to Russia of cultural goods which are on loan in the context of formal cultural cooperation with Russia

[EU FAQs on road transport published on 14 April – accessible here]

Trade restrictions – goods in the Common Military List (exemptions) 15Extension 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.
Financial restrictions – accepting deposits (amendments) 16

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.]

Financial restrictions – sale of transferrable securities / banknotes (amendment) 17

Existing prohibitions (see 25 February below) on:

  • the sale of euro-denominated transferrable securities issued after 12 April 2022 (or related collective investment undertakings) to Russian persons/entities; and
  • the sale/supply of euro-denominated banknotes to Russian persons/entities (including the Russian government and Central Bank) or for use in Russia,

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. 18 ]

EU FAQs on banknotes published on 20 April– accessible here.

Public / concession contracts 19

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:

a) a Russian individual/entity

b) any entity directly or indirectly owned more than 50% by a person/entity in a) or any person/entity acting at their direction/on their behalf.

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:

  • civil nuclear facilities
  • space programmes
  • the provision of strictly necessary goods or services which can only be provided, or which can only be provided in sufficient quantities, by the persons at a) or b)
  • diplomatic/consular purposes
  • the purchase/import of natural gas and oil, including refined petroleum products, titanium, aluminium, copper, nickel, palladium and iron ore from or through Russia into the EU
  • the purchase/import into the EU of coal and other solid fossil fuels (as listed in Annex XXII) until 10 August 2022.

Exemption until 10 October 2022 for contracts concluded before 9 April 2022.

Financial restrictions – financial support 20Prohibition 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.
Trust services 21

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:

a) Russian nationals/residents

b) entities established in Russia

c) entities which are owned (directly or indirectly owned more than 50%) or controlled by, a) or b), or are acting on their behalf/at their direction.

From 10 May 2022   5 July 2022 it will be prohibited to, or arrange for another person to, act as a trustee/nominee/shareholders/director/secretary or similar for such a trust. [Date amended on 3 June 2022 – see above.]

Exemption for actions which are strictly necessary for the termination by 10 May 2022  5 July 2022 of contracts concluded before 9 April 2022. [Date amended on 3 June 2022 – see above.]

Belarus: Financial restrictions - sale of transferrable securities / banknotes (amendment) 22

Existing prohibitions (see 9 March below) on:

  • the sale of euro-denominated transferrable securities issued after 12 April 2022 (or related collective investment undertakings) to Belarusian persons/entities; and
  • the sale/supply of euro-denominated banknotes to Belarusian persons/entities (including the Government and Central Bank) or for use in Belarus,

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. 23]

Belarus: Road transport services – access to EU 24

Prohibition on any Belarusian road transport undertaking to transport goods by road in the EU.

Exemptions for:

  • mail as a universal service
  • until 16 April 2022 to the transport of goods that started before 9 April 2022, provided that the vehicle of the road transport undertaking: (a) was already in the EU on 9 April 2022, or (b) needs to transit through the EU to return to Belarus

Authorisation may be available for:

  • the transport into the EU of natural gas and oil, including refined petroleum products, titanium, aluminium, copper, nickel, palladium and iron ore
  • the transport of pharmaceutical, medical, agricultural and food products, including wheat and fertilisers (provided not otherwise prohibited)
  • humanitarian purposes
  • diplomatic/consular purposes
5 April 2022Guidance: circumvention and due diligence Publication of EU sanctions guidance: "Frequently asked questions on circumvention and due diligence concerning sanctions adopted following Russia’s military aggression against Ukraine".
1 April 2022Notice 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

  • via exports to third countries from where such goods can be diverted easily towards Russia and Belarus; particular attention has to be paid to exports of such goods to countries of the Eurasian Economic Union as goods in any member of the EAEU are in free circulation throughout the EAEU
  • through imports from third countries from where the goods concerned can be diverted easily to the EU, in particular when such countries do not apply restrictions on imports from Russia and Belarus; this is in particular the case of goods imported from other EAEU countries.

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]

28 March 2022Visa 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):

  1. Such investor citizenship schemes are not compatible the Treaty on European Union. Any Member State operating such an investor citizenship scheme should repeal it immediately.
  2. Member States should ensure that all appropriate checks are carried out so as to prevent investor residence schemes from operating in a way that could create risks linked to security, money laundering, tax evasion and corruption.
  3. Any Member State that has naturalised Russian or Belarusian nationals based on an investor citizenship scheme should immediately assess whether these individuals' naturalisations should be withdrawn because the person: (i) is/becomes subject to EU sanctions; or (ii) significantly supports the war in Ukraine.
  4. Member States should immediately withdraw, and refuse to renew, the residence permits granted on the basis of an investor residence scheme to Russian and Belarusian nationals satisfying 3(i) or (ii) above
  5. Member States that operate investor residence schemes should suspend the issuance of residence permits on the basis of investor residence schemes to Russian and Belarusian nationals.
  6. Member States should report to the Commission on the above.
23 March 2022Guidance: Russian state-owned mediaPublication of updated EU sanctions guidance: "Frequently asked questions on restrictions on Russian state-owned media concerning sanctions adopted following Russia’s military aggression against Ukraine"
17 March 2022Oligarch Task Force - meeting

Inaugural ministerial meeting of the Russian Elites, Proxies and Oligarchs Task Force (the "Task Force"). Joint statement confirmed:

  • a commitment to prioritizing resources and working together to take all available legal steps to find, restrain, freeze, seize, and, where appropriate, confiscate or forfeit the assets of those individuals and entities that have been sanctioned in connection with Russia’s invasion of Ukraine; and
  • a commitment to holding accountable those who have complicity in Russia’s unjust war and a determination to deny them the ability to hide and benefit from their assets in all jurisdictions and to undermine the integrity of the international financial system.

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.

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 25

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

Trade restrictions – oil exploration / production 26

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:

  • to the transport of fossil fuels (incl. coal, oil or natural gas) from/through Russia to the EU or in emergencies. [Exemption partially removed / amended on 8 April 2022 – see above]
  • until 17 September 2022 to obligations arising from a contract concluded pre-16 March 2022, subject to a notification requirement.
  • to the provision of insurance or reinsurance to any EU person/entity with regard to its activities outside the energy sector in Russia.
Financial restrictions – investments in Russian energy sector 27

New prohibition on:

  • the acquisition of new, or extension of existing, participation in any Russian entity or any third country operating in the energy sector in Russia.
  • granting new loans or credit or other financing, including equity capital, to any Russian entity or any third country operating in the energy sector in Russia, or for the purpose of financing such an entity.
  • the creation of a new joint venture with to any Russian entity or any third country operating in the energy sector in Russia.

"energy sector" means a sector covering the following activities with the exception of civil nuclear related activities:

a) the exploration, production, distribution within Russia or mining of crude oil, natural gas or solid fossil fuels, the refining of fuels, the liquefaction of natural gas or regasification;

b) the manufacture or distribution within Russia of solid fossil fuel products, refined petroleum products or gas; or

c) the construction of facilities or installation of equipment for, or the provision of services, equipment or technology for, activities related to power generation or electricity production.

Trade restrictionsiron and steel products 28

Prohibition on

  • the import of specified iron and steel products into the EU if they originate in Russia or have been exported from Russia.
  • the purchase such products which are located in, or originate from, Russia.
  • the transport of such products if they originated in Russia or are being exported from Russia to any other country.
  • associated technical/financial services or assistance.

The prohibition shall not apply until 17 June 2022 to obligations arising from a contract concluded pre-16 March 2022.

Trade restrictions – luxury goods 29

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]

Financial restrictions – transactions with state-owned entities 30

Prohibition on engaging in any transaction, directly or indirectly, with 12 specified state-owned entities (as listed in Annex XIX):

  1. OPK Oboronprom
  2. United Aircraft Corporation
  3. Uralvagonzavod
  4. Rosneft
  5. Transneft
  6. Gazprom Neft
  7. Almaz-Antey
  8. Kamaz
  9. Rostec
  10. JSC PO Sevmash
  11. Sovcomflot
  12. United Shipbuilding Corporation

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:

  • until 15 May 2022 to obligations arising from a contract concluded pre-16 March 2022.
  • transactions which are necessary for the purchase of fossil fuels, in particular coal, oil and natural gas, as well as titanium, aluminium, copper, nickel, palladium and iron ore from or through Russia into the EU.
  • transactions relating to energy projects outside Russia in which the above entities are a minority shareholder
Financial restrictions – provision of credit rating services 31

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]

11 March 2022 32

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".]

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.]

9 March 2022

The EU's "Compliance package" of restrictive measures

Financial and investment restrictions - expansion 33Addition 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).
Belarus: Financial restrictions – public/state-owned entities 34

A number of financial prohibitions in respect of Belarusian public or state-owned entities, as follows:

  • prohibition on transactions related to the management of reserves or assets of the Central Bank of Belarus, including transactions with any entity acting on its behalf/at its direction. Note: no start date – appears to apply immediately.
  • prohibition on listing on EU trading venues (and providing services) for the transferable securities of any entity in established in Belarus and with over 50% public ownership from 12 April 2022.
  • prohibition on prohibition on providing public financing or financial assistance for trade with, or investment in, Belarus, subject to certain exceptions (incl. pre-10 March 2022 commitments, investments of less than EUR 10 million for projects benefitting EU SMEs, and food/agriculture/humanitarian/medical purposes)

Definition of "transferrable securities" includes shares, bonds, other securities, and explicitly includes crypto assets.

Belarus: Financial restrictions – accepting deposits 35

Prohibition on accepting deposits from Belarusian nationals/residents, or entities established in Belarus in excess of EUR 100,000 per credit institution.

Exceptions for:

  • nationals or, or persons having temporary residence in, an EU member state, EEA country or Switzerland; and
  • deposits which are necessary for non-prohibited cross-border trade in goods and services between the Union and Belarus.

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.

Belarus: Financial restrictions – other 36

Prohibition on:

  1. EU central securities depositories providing any "services" (as defined in the Annex to Regulation 909/2014) for transferable securities issued after 12 April 2022 to any Belarusian national/resident or entity.
  2. the sale of euro denominated transferable securities issued after 12 April 2022 (or any exposure to such securities) to any Belarusian national/resident or entity.
    (exemption for 1 and 2 for EU nationals/residents.)
  3. the provision of euro denominated banknotes to Belarus or to any Belarusian natural/resident or entity, incl. the Government and the Central Bank of Belarus, or for use in Belarus. Exemption for individual personal use and diplomatic/consular purposes.

[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.]

Belarus: Financial restrictions – SWIFT 37

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:

  • Belagroprombank
  • Bank Dabrabyt
  • Development Bank of the Republic of Belarus’
  • any Belarusian person/entity owned more than 50% by one of the above

 9 March 2022

The EU's "Compliance package" of restrictive measures

Asset freeze 38 - 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
Financial restrictions – amendments/clarifications  39

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.

Trade restrictions – maritime navigation 40

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]

Financial restrictions – Russian National Wealth Fund 41Existing 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.
Financial restrictions – accepting deposits 42

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]

8 March 2022Russian 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:

  1. Diversifying gas supplies, via higher Liquefied Natural Gas (LNG) and pipeline imports from non-Russian suppliers, and larger volumes of biomethane and renewable hydrogen production and imports; and
  2. Reducing faster the use of fossil fuels in our homes, buildings, industry, and power system, by boosting energy efficiency, increasing renewables and electrification, and addressing infrastructure bottlenecks.

2 March 2022

The EU's "third package" of restrictive measures (part 2)

Financial restrictions – SWIFT access 43

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:

  • Bank Otkritie
  • Novikombank
  • Promsvyazbank
  • Bank Rossiya
  • Sovcombank
  • Vnesheconombank (VEB)
  • VTB Bank

[Note: Sberbank and Gazprombank have been excluded from these restrictions.]

[EU FAQs on SWIFT published on 19 April – accessible here]

Financial restrictions – euro denominated banknotes 44

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.

  • Exceptions: Personal use for individuals travelling to Russia/their families, and diplomatic/consular purposes.

Financial restrictions – Russian Direct Investment Fund 45

Prohibition on investment, participation or other contribution to projects co-financed by the Russian Direct Investment Fund.

Media ban 46

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]

Asset freeze 47

21 individuals: senior Belarusian ministers/military personnel

Trade restrictions – Belarus

(in view of the involvement of Belarus in the Russian aggression against Ukraine)

Prohibition on the sale/supply of:

  • dual-use goods and technology, whether or not originating in the EU, to any person/body in Belarus or for use in Belarus, or any related technical or financial assistance.
  • certain listed goods and technology which might contribute to Belarus’s military and technological enhancement, or to the development of its defence and security sector.

Exceptions for, for example, humanitarian, non-military, consumer communication, medical or temporary media use. Authorisations possible in certain circumstances.

28 February 2022

The EU's "third package" of restrictive measures (part 1)

Airspace ban 48

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.

Financial restrictions – Central Bank of Russia 49

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.

[Amended to include the Russian National Wealth Fund on 9 March 2022 – see above.]

[EU FAQs on the Central Bank of Russia published on 20 April – accessible here]

Asset freeze 50

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

27 February 2022
(announced but not yet implemented) 51

Trade restrictions – Belarus 

A new package of sanctions aimed at Lukashenko's regime, including:

  • restrictive measures against important sectors, such as mineral fuels, tobacco, wood and timber, cement, iron and steel.

26 February 2022 52

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:

  • 9 March 2022: the requirement for EU financial institutions to provide certain information about individuals with "golden passports" (see above).
  • 28 March 2022: Commission recommendation to Member States to review / repeal / suspend investor residence schemes, in particular in respect of Russian and Belarusian individuals (see above).

25 February 2022

The EU's "second package" of restrictive measures

Trade restrictions – dual-use, military and oil refining 53

Ban on the sale/supply, and/or any related technical or financial assistance, in respect of:

a) dual-use goods and technology to any natural or legal person, entity or body in Russia or for use in Russia.

b) certain listed goods or technology which "might contribute to Russia's military and technological enhancement, or the development of the defence and security sector".

(The supply of a) or b) for non-military purposes under pre-26 February 2022 contracts can be authorised pre-1 May 2022.)

c) certain listed goods or technology for use in oil refining (does not apply to contracts concluded pre-26 February 2022 until 27 May 2022).

d) certain listed goods or technology suited for use in aviation or the space industry, including the repair/modification of such goods (does not apply to contracts concluded pre-26 February 2022 until 28 March 2022).

There are certain exceptions, including for humanitarian, medical and/or consumer purposes (subject to approvals).

Ban on public funding/financial assistance 54

Prohibition on the provision of public financing or financial assistance for trade with, or investment in, Russia, subject to certain exceptions:

  • pre-26 February commitments;
  • public financing/financial assistance of less than EUR10 million; and/or
  • public financing/financial assistance for trade in food, and for agricultural, medical or humanitarian purposes

[Amended on 9 March 2022 – see above.]
 

Financial and investment restrictions (prohibition on new loans / dealing with securities) 55

Extended the existing capital markets prohibition, as follows:

  1. Prohibition on all dealings with transferable securities and money-market instruments (i) with a maturity exceeding 90 days, issued after 1 August 2014 to 12 September 2014; (ii) with a maturity exceeding 30 days, issued after 12 September 2014 to 12 April 2022; or (iii) any transferable securities and money market instruments issued after 12 April 2022, by:
    • Sberbank, VTB Bank, Gazprombank, Vnesheconombank (VEB) and Rosselkhozbank (the "Annex III Banks"), or any person/entity owned (more than 50%) by, or acting at the direction of them [Note: These banks were previously subject to capital markets restrictions]; or
  2. Prohibition on all dealings with transferable securities and money-market instruments issued after 12 April 2022 by:
    • Alfa Bank, Bank Otkritie, Bank Rossiya, and Promsvyazbank (the "Annex XII Banks"), or any person/entity owned (more than 50%) by, or acting at the direction of them [Note: These banks were not previously subject to capital markets restrictions].
  3. Prohibition on all dealings with transferable securities and money-market instruments (i) with a maturity exceeding 30 days, issued after 12 September 2014 to 12 April 2022; or (ii) any transferable securities and money market instruments issued after 12 April 2022, by:
    • Oboronprom, United Aircraft Corp, Uralvagonzavod (with an exception for entities bodies active in the space or the nuclear energy sectors) (the "Annex V Entities") [Note: These entities were previously subject to capital markets restrictions];
    • Rosneft, Transneft, and Gazprom Neft (the "Annex VI Entities") [Note: These entities were previously subject to capital markets restrictions];
    • or any person/entity owned (more than 50%) by, or acting at the direction of the Annex V or VI Entities.
  4. Prohibition on all dealings with transferable securities and money-market instruments issued after 12 April 2022 by:
    • Almaz-Antey; Kamaz; Novorossiysk Commercial Sea Port; Rostec (Russian Technologies State Corporation); Russian Railways; JSC PO Sevmash; Sovcomflot; and United Shipbuilding Corporation (the "Annex XIII Entities"), or any person/entity owned (more than 50%) by, or acting at the direction of them.

      [Annex XIII Entities updated on 9 March 2022 to include the Russian Maritime Register of Shipping]

  5. Prohibition on the listing by any trading venues in the EU of any transferrable securities by any Russian entity with more than 50 per cent public ownership.
  6. Prohibition on being part of any arrangement to make:
    • new loans or credit with a maturity exceeding 30 days, to any entity referred to in paragraphs 1 or 3 above, after 12 September 2014 to 26 February 2022; and
    • any new loans or credit to any entity referred to in paragraphs 1 to 4 above after 26 February 2022,
    subject to certain – very specific – exceptions, including in respect of pre-26 February 2022 contracts.

Financial restrictions - banking facilities/deposits 56

Prohibition on:

  • acceptance of deposits from Russian nationals/residents or entities established in Russia of over EUR 100,000. Authorisations available for, e.g. to satisfy basic needs.
  • the provision by EU central securities depositories of services for transferable securities after 12 April 2022 to Russian nationals/residents or entities established in Russia.
  • the sale of sell euro denominated transferable securities issued after 12 April 2022 or units in collective investment undertakings providing exposure to such securities to Russian nationals/residents or entities established in Russia.

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.

Additional basis for designation under Council Regulation (EU) No 269/2014 57

Added three additional grounds for designation under Annex I of Regulation 269/2014:

  • persons/entities conducting transactions with the separatist groups in the Donbas region of Ukraine;
  • persons/entities supporting, materially or financially, or benefitting from the Government of the Russian Federation; or
  • leading businesspersons or persons/entities involved in economic sectors providing a substantial source of revenue to the Government of the Russian Federation.

Asset freeze  58

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.

Visa restrictions 59

Suspension of certain provisions of the Agreements  60 between the EC/EU and Russia regarding the issuance of visas – essentially, those provisions allowing visa-free travel - including certain provisions in relation to:

  • members of the Russian Federation's official delegations, national and regional Governments and Parliaments, Constitutional and Supreme Courts;
  • Russian diplomats; and
  • business people.

23 February 2022

The EU's "first package" of restrictive measures

Asset freeze 61

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. 62

Asset freeze 63

336 individual members of Russia State Duma.

Financial and investment restrictions (prohibition on new loans / dealing with securities) 64

Introduced a new prohibition on dealings with transferable securities and money-market instruments issued after 9 March 2022 by:
  • Russia and its government; and/or
  • the Central Bank of Russia,
and/or any new loans/credit to those entities after 23 February 2022.

Sectoral sanctions - Donetsk and Luhansk regions 65

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:

  • the acquisition of real estate
  • provision of financing to entities in those regions
  • creation of a joint venture
  • provision of investment services in respect of the same.

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 pubished on 30 March – accessible here]

Footnotes

4. Council Regulation (EU) 2022/625 of 13 April 2022 amending Regulation (EU) No 269/2014 – new Article 2a
5. Council Implementing Regulation (EU) 2022/581 of 8 April 2022 implementing Regulation (EU) No 269/2014
6. Council Implementing Regulation (EU) 2022/580 of 8 April 2022 implementing Regulation (EU) No 269/2014
7. Council Regulation (EU) 2022/576 of 8 April 2022 amending Regulation (EU) No 833/2014
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 – new Article 3i
13. Council Regulation (EU) 2022/576 of 8 April 2022 amending Regulation (EU) No 833/2014 – new Article 3k
14. Council Regulation (EU) 2022/576 of 8 April 2022 amending Regulation (EU) No 833/2014 – new Article 3l
15. Council Regulation (EU) 2022/576 of 8 April 2022 amending Regulation (EU) No 833/2014
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. https://european-union.europa.eu/institutions-law-budget/euro/countries-using-euro_en
19 Council Regulation (EU) 2022/576 of 8 April 2022 amending Regulation (EU) No 833/2014 – new Article 5k
20. Council Regulation (EU) 2022/576 of 8 April 2022 amending Regulation (EU) No 833/2014 – new Article 5l
21. Council Regulation (EU) 2022/576 of 8 April 2022 amending Regulation (EU) No 833/2014 – new Article 5m
22. COUNCIL REGULATION (EU) 2022/577 of 8 April 2022 amending Regulation (EC) No 765/2006
23. https://european-union.europa.eu/institutions-law-budget/euro/countries-using-euro_en
24. COUNCIL REGULATION (EU) 2022/577 of 8 April 2022 amending Regulation (EC) No 765/2006
25. Council Implementing Regulation (EU) 2022/427 of 15 March 2022 implementing Regulation (EU) No 269/2014
26. Council Regulation (EU) 2022/428 of 15 March 2022 amending Regulation (EU) No 833/2014 - replacement Article 3
27. Council Regulation (EU) 2022/428 of 15 March 2022 amending Regulation (EU) No 833/2014 - replacement Article 3a
28. Council Regulation (EU) 2022/428 of 15 March 2022 amending Regulation (EU) No 833/2014 - new Article 3g
29. Council Regulation (EU) 2022/428 of 15 March 2022 amending Regulation (EU) No 833/2014 - new Article 3h and Annex XVIII
30. Council Regulation (EU) 2022/428 of 15 March 2022 amending Regulation (EU) No 833/2014 - new Article 5aa and Annex XIX
31. Council Regulation (EU) 2022/428 of 15 March 2022 amending Regulation (EU) No 833/2014 - new Article 5j
32.Any measures which have been implemented since their announcement have not been listed here.
33. Council Regulation (EU) 2022/394 of 9 March 2022 amending Regulation (EU) No 833/2014 – amendment to Annex XIII
34. Council Regulation (EU) 2022/398 of 9 March 2022 amending Regulation (EC) No 765/2006
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 Implementing Regulation (EU) 2022/396 of 9 March 2022 implementing Regulation (EU) No 269/2014
39. Council Regulation (EU) 2022/394 of 9 March 2022 amending Regulation (EU) No 833/2014 – amendment to Article 2e
40. Council Regulation (EU) 2022/394 of 9 March 2022 amending Regulation (EU) No 833/2014 – new Article 3f
41. Council Regulation (EU) 2022/394 of 9 March 2022 amending Regulation (EU) No 833/2014 – amendment to Article 5a
42. Council Regulation (EU) 2022/394 of 9 March 2022 amending Regulation (EU) No 833/2014 – amendment to Article 5b
43. Council Regulation (EU) 2022/345 of 1 March 2022 amending Regulation (EU) No 833/2014 – new Article 5h
44. Council Regulation (EU) 2022/345 of 1 March 2022 amending Regulation (EU) No 833/2014 – new Article 5i
45. Council Regulation (EU) 2022/345 of 1 March 2022 amending Regulation (EU) No 833/2014 – amendment to Article 2e
46. Council Regulation (EU) 2022/350 of 1 March 2022 amending Regulation (EU) No 833/2014 – new Article 2f
47. Council Implementing Regulation (EU) 2022/353 of 2 March 2022 Implementing Regulation (EU) No 269/2014
48. Council Regulation (EU) 2022/334 of 28 February 2022 amending Council Regulation (EU) No 833/2014 – new Article 3d and e
49. Council Regulation (EU) 2022/334 of 28 February 2022 amending Council Regulation (EU) No 833/2014 – amendments to Article 5a
50. Council Implementing Regulation (EU) 2022/336 of 28 February 2022 implementing Regulation (EU) No 269/2014
51. Any measures which have been implemented since their announcement have not been listed here.
52. Any measures which have been implemented since their announcement have not been listed here.
53. Council Regulation (EU) 2022/328 of 25 February 2022 amending Regulation (EU) No 833/2014 – updated/new Articles 2, 2a-d, 3b-c
54. Council Regulation (EU) 2022/328 of 25 February 2022 amending Regulation (EU) No 833/2014 – new Article 2e
55. Council Regulation (EU) 2022/328 of 25 February 2022 amending Regulation (EU) No 833/2014 – amendments to Article 5
56. Council Regulation (EU) 2022/328 of 25 February 2022 amending Regulation (EU) No 833/2014 – new Articles 5b-g
57. Council Regulation (EU) 2022/330 of 25 February 2022 amending Regulation (EU) No 269/2014
58. Council Implementing Regulation (EU) 2022/332 of 25 February 2022 implementing Regulation (EU) No 269/2014
59. Council Decision (EU) 2022/333 of 25 February 2022
60. 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
61. Council Implementing Regulation (EU) 2022/260 of 23 February 2022 implementing Regulation (EU) No 269/2014
62. Council Implementing Regulation (EU) 2022/259 of 23 February 2022 implementing Regulation (EU) No 269/2014
63. Council Implementing Regulation (EU) 2022/261 of 23 February 2022 implementing Regulation (EU) No 269/2014
64. Council Regulation (EU) 2022/262 of 23 February 2022 amending Regulation (EU) No 833/2014 (reflecting the adoption of Council Decision (CFSP) 2022/264)
65. Council Regulation (EU) 2022/263 of 23 February 2022

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