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In response to the Russian Federation’s activities targeting Ukraine and the recognition of Luhansk/Donetsk as independent regions, EU foreign ministers have authorized eleven packages of sanctions. The packages include several regulations limiting Russia’s access to the capital market. Moreover, they include financial sanctions against certain individuals and companies as well as export bans and implement a price cap on Russian crude oil and certain oil products. Violations are subject to severe penalties.
In the following, we provide a general overview of the sanctions regime and explain what companies need to do now.
I. New Sanctions
First package of Sanctions
1. Restrictions of the capital market (Regulation (EU) 2022/262)
EU Official Journal Nr. L 42I, 02-23-2022, P. 74-76: Regulation(EU) 2022/262
2. Financial sanctions against natural persons and companies (Regulation (EU) 2022/260, 2022/261 and extended by the following packages of sanctions)
EU Official Journal Nr. L 42I, 02-23-2022, P. 15-73: Regulation (EU) 2022/260; EU Official Journal Nr. L 42I, 02-23-2022, P. 3-14: Regulation (EU) 2022/261; EU Official Journal Nr. L 53, 02-25-2022, S. 1-44: Regulation (EU) 2022/332; EU Official Journal Nr. L 58, 02-28-2022, P.1-18: Regulation (EU) 2022/336; EU Official Journal Nr. L 66, 03-02-2022, P. 1-13: Regulation (EU) 2022/353; EU Official Journal Nr. L 80, 09-03-2022, P. 1-30: Regulation (EU) 2022/396; EU Official Journal Nr. L 84, 03-11-2022, P. 2-17: Regulation (EU) 2022/408; EU Official Journal Nr. L 87I, 03-13-2022, P.1-12: Regulation (EU) 2022/427
3. Regional sanctions concerning Luhansk/Donetsk (Regulation (EU) 2022/263)
EU Official Journal Nr. L 42I, 02-23-2022, P. 77-94: Regulation EU 2022/263
Second package of Sanctions
On February 24, the EU foreign ministers decided to impose additional sanctions (Regulation (EU) 2022/328).
Third package of Sanctions
In response to continued attacks by Russian forces in Ukraine, the United States, France, Canada, Italy, the United Kingdom, the EU Commission and Germany agreed on further financial sanctions against Russia on February 26, 2022.
The following Russian banks are excluded from the international payment service system “Swift”: Bank Otkritie, Novikombank, Promsvyazbank, Bank Rossiya, Sovcombank, Vnesheconombank (VEB), VTB Bank. These institutions shall be excluded from international financial flows and their global operations shall be restricted. No euro banknotes may be delivered to Russia (EU Official Journal Nr. L 63, 28-02-2022, P.1-4: Regulation (EU) 2022/345).
It was decided to further restrict the Russian Central Bank’s ability to support the ruble’s exchange rate with international financial transactions. There is a ban on transactions related to the management of reserves and assets of the Central Bank of Russia, as well as on transactions with legal persons or entities acting on behalf of or at the direction of the Central Bank of Russia (e.g. the Russian National Wealth Fund) (EU Official Journal, Nr. L 57, 28-02-2022, P. 1-3: Regulation (EU) 2022/334; EU Official Journal Nr. L 81, 09-03-2022, P. 1-7: Regulation 2022/394).
A task force with representatives from the U.S. and the EU will be established to ensure a quick implementation of the sanctions and to freeze the assets of sanctioned individuals, their families and companies.
Fourth package of Sanctions
The EU has agreed on a fourth package of sanctions against Russia (EU Official Journal Nr. L 87I, 03-15-2022, P. 13-43: Regulation (EU) 2022/428).
Fifth package of Sanctions
The EU has adopted a fifth package sanctions against Russia with the following measures. This fifth package includes six pillars (EU Official Journal Nr. L 111, 04-08-2022, P. 1-66: Regulation (EU) 2022/576):
Finally, additional natural and legal persons are also added to the European sanctions list. These are thus subject to the so-called ban on provision (see comments above).
Sixth package of Sanctions
On the night of May 30-31, 2022, the European Council agreed on a sixth package of sanctions against Russia, including the following measures (EU Official Journal Nr. L 153, 06-03-2022, P. 53-74: Regulation (EU) 2022/879):
Seventh package of Sanctions
On July 21, 2022, the regulation regarding the seventh package of sanctions was adopted. The sanctions became effective on July 22, 2022 and include the following measures (EU Official Journal Nr. L 193, 07-21-2022, P. 1-132: Regulation (EU) 2022/1269):
Eighth package of Sanctions
In response to Russia’s recent actions to destabilize Ukraine, European Council passed it eighth package of sanctions on October 6, 2022, extending current sanctions and implementing new ones. In particular, they take Russia’s further aggression against Ukraine, the organization of illegal sham 'referenda' in the parts of the Donetsk, Kherson, Luhansk and Zaporizhzhia regions that are currently illegally occupied by Russia, the illegal annexation of those Ukrainian regions by Russia, as well as the mobilization in Russia and its repeated threat to use weapons of mass destruction into consideration (EU Official Journal Nr. LI 259/3, 06-10-2022, P. 3-75: Regulation (EU) 2022/1904):
Ninth package of Sanctions
On December 16, 2022, the Regulation regarding the ninth package of sanctions was adopted. The sanctions entered into force on December 17, 2022 and include, in particular, the following measures (EU Official Journal No. L 322, 16.12.2022, p. 1-314; Regulation (EU) 2022/2474):
Tenth package of Sancations
In regards to the ongoing combating actions in Ukraine, the Council of the European Union, passed a new sanction package in form of Council Regulation (EU) No. 2023/427 dated on 25 February 2023, the content of which alternates some of the requirements first shaped in Council Regulation (EU) Nr. 833/2014. The essential renewals and adjustments are reflected as following:
11th package of Sancations
On 23 June 2023, the Council of the European Union passed its 11th package of sanctions against Russia (Regulation (EU) 2023/1214 amending Regulation (EU) 833/2014). The package aims to ensure that EU sanctions against Russia are better enforced and circumventions prevented. In this context, the restriction of goods deliveries to third countries is now exceptionally possible. The sanctions came into force on 24 June 2023 and include, in particular, the following measures:
Sanctions against Belarus
2. Already existing sanctions of the EU against Russia
Finally, there are regional sanctions concerning Crimea/Sevastopol (Regulation (EU) 692/2014), including a ban on import of goods originating in Crimea/Sevastopol and a ban on export of goods and technology listed in Annex III to natural persons or legal entities in Crimea or Sevastopol.
3. To Dos’ for my company?
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