New EU sanctions against Russia

On 25 February 2023, one year after Russia started its invasion of Ukraine, the EU adopted its tenth sanctions package against Russia. Together with the existing sanctions the European Commission considers the entirety of the measures imposed on Russia  (see also our Handling EU sanctions website) to be the toughest sanctions ever introduced by the EU.

The tenth sanctions package has the following four main elements:

• widens export bans;
• widens import restrictions;
• lists additional individuals and entities; and
• takes a tougher stance on circumvention.

Export bans

The EU imposed new export bans. These export bans cover goods and technology with an estimated worth of more than EUR 11 billion. The focus is on dual-use and other critical technology and industrial goods, in particular:

• electronics and electronic components (e.g. for drones, missiles or helicopters);
• specialised vehicles;
• machine parts;
• spare parts for trucks;
• jet engines;
• goods for the construction sector;
• raw earth materials; and
• complete industrial plants.

Regarding dual-use goods and technology and arms, the mere transit of these via Russia is now prohibited to avoid circumvention. Furthermore, 96 entities have been added to the list of companies, which are subject to particularly strict export restrictions. This list now curiously includes seven Iranian entities (manufacturers of unmanned aerial vehicles, i.e. drones) since these have supported the Russian military.

Import Restrictions

The existing import restrictions on goods generating significant revenues for Russia have been widened to include additional products from the petroleum industry such as petroleum coke, bitumen, asphalt and synthetic rubber with an additional worth of almost EUR 1.3 billion.

Sanctions on individuals and entities

The EU has listed another 87 individuals for financial sanctions. Such financial sanctions, which include asset freezes and prohibitions on making funds and economic resources available, already were in place for 1,386 individuals and 171 entities. The newly added individuals are mostly propagandists as well as additional military and political commanders, including members of the proxy governments of the illegally annexed Ukrainian regions of Luhansk, Donetsk, Kherson and Zaporizhzhia and judges in these regions. The EU also added 34 additional entities, most notably three Russian banks;

• Alfa-Bank;
• Rosbank; and
• Tinkoff Bank.

Tackling circumvention

The EU remains extremely concerned about circumvention of the sanctions. The new sanctions package therefore imposes measures aimed at more effectively tracking assets located in the EU of oligarchs and in particular of the Russian Central Bank. These include reporting obligations on Russian Central Bank assets, frozen assets or assets that should be frozen and a pre-flight notification obligation for non-scheduled flights between Russia and the EU.

Additional measures

Additional measures address public order and security concerns of the EU and its member states. Broadcasting licences of the Arabic versions of Russia Today and Sputnik were added. Furthermore, Russian nationals or persons residing in Russia (except persons who are (also) nationals of EU, EEA and Switzerland) will be prohibited from holding any posts in the governing bodies of the owners or operators of certain critical infrastructures in the EU as of 27 March 2023. The provision of gas storage capacity (except for the part of LNG facilities) has also been restricted for Russian nationals, entities or bodies, or entities owned or controlled by them or acting on their behalf.

Parallel to the tenth sanctions package against Russia, the EU has also imposed financial sanctions on additional members and supporters of the Wagner mercenary group under the Mali Sanctions regime and under the global EU Human Rights Sanctions regime due to their activities beyond Ukraine in Libya, the Central African Republic (CAR), Mali and Sudan. The Wagner Group itself has already been listed under the thematic human rights sanction regime since December 2021.

For more information on this topic, see our “Handling EU sanctions website” and contact your usual CMS contacts or local sanctions experts.