On the one-year anniversary of Russia’s invasion of Ukraine, the European Union adopts the 10th package of restrictive measures against Russia, increasing the pressure on the Russian Government and those responsible for Russia’s continuing war of aggression.

The 10th package was introduced in the EU press release on the 25th of February 2023 and includes the following new measures:

• Additional listings: Around 120 individuals and entities were included by the EU in the sanctions list, including Russian decision-makers, senior government officials and military leaders complicit in the war against Ukraine, as well as proxy authorities installed by Russia in the occupied territories in Ukraine, among others. The list also includes key figures involved in the kidnapping of Ukrainian children to Russia, as well as organisations and individuals, who are polluting the public space with disinformation, adding to the military warfare through information warfare.
•  Additional EU export bans: New export restrictions have been introduced on sensitive dual-use and advanced technologies that contribute to Russia's military capabilities and technological enhancement such as electronics, drones, specialised vehicles, machine parts, spare parts for trucks and jet engines, as well as goods for the construction sector which can be directed to Russia's military, such as antennas or cranes. Bans have also been placed on specific rare earths and thermal cameras with military applications. An additional 96 entities associated to Russia's military-industrial complex were also listed in the 10th package.

Additional export bans are now also imposed on goods that can be easily redirected to be used to support the Russian war effort including:

1. vehicles: heavy trucks not yet banned (and their spare parts), semi-trailers, and special vehicles such as snowmobiles
2. goods easily directed to the Russian military: including electric generators, binoculars, radars, compass, etc
3. construction goods such as bridges, structures for buildings tower-like, fork-lifts trucks, cranes, etc.
4. goods that are critical for the functioning and enhancement of Russian industrial capacity (electronics, machine parts, pumps, machinery for working metals, etc.)
5. complete industrial plants;
6. goods used in the aviation industry (turbojets)

With this 10th package, the EU has sanctioned in total nearly close to half (49%) of its 2021 exports to Russia.

• Additional imports bans into the EU: the 10th package imposes import bans on the following Russian high-revenue goods

1. bitumen and related materials like asphalt
2. synthetic rubber and carbon blacks

With this 10th package the import bans represent altogether 58% of the EU's 2021 imports.

• Financial sector: Three Russian banks, Alfa-Bank, Rosbank and Tinkoff Bank, have been added to the list of entities subject to the asset freeze and the prohibition to make funds and economic resources available.
  
  
• Other measures include the following:
  
  

-       a ban on Russian nationals from serving on governing bodies of Member States' critical infrastructure companies;

-       prohibition on Russian nationals and entities to book gas storage capacity in the Union (LNG excluded);

-       measures to facilitate the divestment from Russia by EU operators;

-       A third country shipping company, suspected of helping Russia circumvent sanctions on oil exports, has also been listed.

• Enforcement and anti-circumvention measures: The 10th package imposes new reporting obligations on Russian Central Bank assets. This is especially important regarding the possible use of public Russian assets to fund the reconstruction of Ukraine after Russia is defeated.

Other measures include the following:

-       reporting obligations on frozen assets (including for dealings before listings) and assets which should be frozen;

-       private flights between the EU and Russia, directly or via third countries, should be notified in advance;

-       prohibition to transit dual use goods and firearms via the territory of Russia to third countries.

• Additional bans on Russian disinformation outlets: Two additional Russian media outlets have been added to the media ban, RT Arabic and Sputnik Arabic. In line with the Charter of Fundamental Rights, these measures will not prevent those media outlets and their staff from carrying out activities in the EU other than broadcasting, e.g. research and interviews.
  
  
• Technical amendments
  
  

-       an amendment has been made to allow the provision of pilot services necessary for maritime safety;

-       a definition of the term “import” was included so as to avoid goods being “stranded” in long customs procedures.

It is also worth mentioning that the EU sanctions envoy, David O'Sullivan, is reaching out to third countries, to ensure strict implementation of sanctions and prevent circumvention. On 23 February, the first Sanctions Coordinators Forum took place in Brussels, gathering EU’s international partners and Member States, to strengthen enforcement efforts.

The impact of the EU sanctions packages is evident in the professional and business world and our task to keep up to date and ensure compliance only becomes stricter while the scope of the continuous restrictive measures extends and becomes far reaching.

Please see here for relevant Regulations and Council decisions.

Source: the European Commission website, Timeline on measures adopted in 2022-2023

Author

Andrea Ioakim

Partner

Andrea.Ioakim@kinanis.com