Restrictive measures against Russia

In light of the actions of Russia, which destabilised the situation in Ukraine, the EU first introduced economic restrictive measures against Russia on 31 July 2014 via Regulation (EU) 833/2014 and Council Decision 2014/512/CFSP, which entered into force on 1 August 2014. When Russia recognised the non-government controlled areas of the Donetsk and Luhansk oblasts of Ukraine and then began its military aggression against Ukraine, the EU responded with various restrictive measures. The measures are continuing to be tightened and expanded. 

A quick overview of the current restrictive measures against Russia can be found in the infographic on the Council of the EU website: EU sanctions against Russia over Ukraine - Consilium (europa.eu). This also provides a timeline of the adoption of new restrictive measures: Sanctions adopted following Russia’s military aggression against Ukraine | European Commission (europa.eu).

 

New sanctions by area

Sanctions are listed in this PDF document.

 

New sanctions in chronological order with links to the EU regulations

21 July 2022

The Council of the EU adopted Regulation 2022/1269 amending Regulation 833/2014, with effect from 22 July 2022. The most important changes are:

  • Gold import ban: The import of all gold originating from Russia and exported from Russia into the EU or to any third country is prohibited. An exemption applies for gold jewellery of travellers for their personal use; Art. 3o.
  • Reporting requirements strengthened: Sanctioned people are obliged to declare their assets, in order to facilitate the freezing of their assets in the EU.
  • Targeted export bans: Export controls on dual use and advanced technology is reinforced by extending the list of items which may contribute to Russia’s military and technological enhancement or the development of its defence and security sector.
  • Port access ban: Russian flagged vessels are banned to access locks to prevent the circumvention of sanctions; Art. 3ea.
  • Financial sanctions: The prohibition on accepting deposits is expanded to deposits from legal persons, entities or bodies established in third countries and majority-owned by Russian nationals or natural persons residing in Russia. Additionally, the acceptance of deposits for non-prohibited cross-border trade will be subject to a prior authorisation by the national competent authorities; Art. 5b
  • Food and energy security: Transactions for agricultural products and the transport of oil to third countries with certain state-owned entities are exempted
  • Medical and pharmaceutical exemptions: Exemptions are added for certain export prohibitions for medical and pharmaceutical purposes
  • Clarifications: introduction of a number of clarifications to existing measures, for instance in the field of public procurement, aviation and justice

In accordance with Council Implementing Regulation 2022/1270 further 54 individuals and 10 entities were added on the list.

3 June 2022

The Council of the EU adopted Regulation 2022/879 amending Regulation 833/2014, with effect from 4 June 2022. The most important changes are:

  • A partial ban on imports of Russian oil into the EU is adopted, which will initially only include oil imported by sea. However, crude oil delivered via pipelines will be temporarily exempted. Due to its specific geographical exposure, a special temporary derogation has been agreed for Bulgaria until the end of 2024, which will be able to continue importing crude oil and petroleum products via sea freight. In addition, Croatia will be able to authorise imports of Russian vacuum gas oil, which is necessary for the operation of its refinery, until the end of 2023.
  • After a wind down period of 6 months, EU operators will be prohibited from insuring and financing the transport, in particular through maritime routes, of oil to third countries.
  • An additional 3 Russian banks, including Russia's largest bank Sberbank, have been removed from SWIFT.
  • The provision of certain business-relevant services - directly or indirectly – such as accounting, auditing, statutory audit, bookkeeping and tax consulting services, business and management consulting, and public relations services to the Russian government, as well as to legal persons, entities or bodies established in Russia are now prohibited.
  • The broadcasting activities of another 3 Russian State outlets – Rossiya RTR/RTR Planeta, Rossiya 24/Russia 24, and TV Centre International – have been suspended.
  • The list of advanced technology items banned from export to Russia has been expanded to include additional chemicals that could be used in the process of manufacture of chemical weapons.
  • Another 65 individuals and 18 entities responsible for atrocities committed by Russian troops in Buche and Mariupol have been added to the sanctions list.

8 April 2022

  • 217 more individuals and 18 entities are added to the sanctions list. Among entities there are also 4 banks. After being de-SWIFTed these banks are now subject to an asset freeze, thereby being completely cut off from EU markets (Council implementing regulation 2022/581 of 8 April 2022 implementing Regulation (EU) No 269/2014; Annex I).
  • A prohibition to purchase, import or transfer coal and other solid fossil fuels into the EU if they originate in Russia or are exported from Russia, as from August 2022 (Regulation 2022/576 amending Regulation 833/2014; Art. 3j).
  • A prohibition to provide access to EU ports to vessels registered under the flag of Russia. Derogations are granted for agricultural and food products, humanitarian aid, and energy (Regulation 2022/576 amending Regulation 833/2014; Art. 3 ea).
  • A ban on any Russian road transport undertaking preventing them from transporting goods by road within the EU, including in transit. Derogations are nonetheless granted for a number of products, such as pharmaceutical, medical, agricultural and food products, including wheat, and for road transport for humanitarian purposes (Regulation 2022/576 amending Regulation 833/2014; Art. 3l).
  • Further export bans, targeting jet fuel and other goods such as quantum computers and advanced semiconductors, high-end electronics, software, sensitive machinery and transportation equipment, and new import bans on products such as: wood, cement, fertilisers, seafood and liquor. (Regulation 2022/576 amending Regulation 833/2014; Art. 3k in connection with Annex XXIII).
  • New bans on imports of goods that generate significant revenues for Russia and thus enable it to operate, destabilising the situation in Ukraine, such as: timber, cement, fertilisers, seafood and alcoholic beverages (Regulation 2022/576 amending Regulation 833/2014; Art. 3i in connection with Annex XXI).
  • Prohibition to register, provide a registered office, business or administrative address as well as management services to, a trust or any similar legal arrangement having as a trustor or a beneficiary (Regulation 2022/576 amending Regulation 833/2014; Art. 5m).
  • A general EU ban on participation of Russian companies in public procurement and concession contract in member states (Regulation 2022/576 amending Regulation 833/2014; Art. 5k).
  • Prohibition on providing crypto-asset wallet, account or custody services to Russian nationals or natural persons residing in Russia, or legal persons, entities or bodies established in Russia, if the total value of crypto-assets of the natural or legal person, entity or body per wallet, account or custody provider exceeds EUR 10.000 (Regulation 2022/576 amending Regulation 833/2014; Art. 5b(2)).
  • Prohibition on the sale of banknotes denominated in any official currencies of the EU member states to Russia or to any natural or legal person, entity or body in Russia (Regulation 2022/576 amending Regulation 833/2014; Art. 5i).
  • Prohibition on the sale of transferrable securities denominated in any official currencies of the EU member states to Russia and Belarus, or to any natural or legal person, entity or body in Russia (Regulation 2022/576 amending Regulation 833/2014; Art. 5f(1)).
  • Prohibition of public subsidies or subsidy programmes at EU or national level in favour of of Russian public institutions (Regulation 2022/576 amending Regulation 833/2014; Art. 5l).

 

15 March 2022 

  • 15 more individuals and 9 entities are added to the sanctions list (Council Implementing Regulation (EU) 2022/427 of 15 March 2022 implementing Regulation (EU) No 269/2014). 
  • Investments and joint ventures with Russian entities operating in the energy sector, and the financing and provision of loans or credits to such entities, are prohibited. The prohibition shall take effect from the date of entry into force of the amendments to the Regulation. It shall also be prohibited to create any new joint venture with any legal person, entity or body incorporated or constituted under the law of Russia or any third country and active in the energy sector in Russia (Regulation 2022/428 amending Regulation 833/2014; Art. 3a).
  • It shall be prohibited to import, directly or indirectly, iron and steel products into the Union and to transport them to another country if they originate in Russia or have been exported from Russia. It shall be prohibited to purchase iron and steel products located in Russia or originating in Russia (Regulation 2022/428 amending Regulation 833/2014; Art. 3g in connection with Annex XVII).
  • It shall be prohibited to sell, supply, transfer or export, directly or indirectly, luxury goods to any natural or legal person, entity or body in Russia or for use in Russia (if their value exceeds EUR 300 per item) (Regulation 2022/428 amending Regulation 833/2014; new Art. 3h in connection with Annex XVIII).
  • It shall be prohibited to engage, directly or indirectly, in any transaction with a legal person, entity or body domiciled in Russia that is publicly controlled or more than 50 % publicly owned, or in which Russia, its government or central bank has a profit-sharing right or other significant economic relationship with Russia, or with a legal person, entity or body acting on behalf of, or at the direction of, such entities. (Regulation 2022/428 amending Regulation 833/2014; new Art. 5aa in connection with Annex XIX).
  • As of 15 April 2022, the granting of credit ratings and access to subscriptions to credit rating and analysis information to any entity in Russia is prohibited The prohibition does not apply to nationals of a Member State or natural persons holding a temporary or permanent residence permit in a Member State. (Regulation 2022/428 amending Regulation 833/2014; new Art. 5j).

 

 9 March 2022

  • Listing 46 members of the Council of the Russian Federation which ratified the government decisions on the 'Treaty of Friendship, Cooperation and Mutual Assistance between the Russian Federation and the Donetsk People's Republic and between the Russian Federation and the Luhansk People's Republic', and 14 persons supporting and benefiting from the Government of the Russian Federation, or providing it with a substantial source of income, or associated with persons or entities on the list (Council Implementing Regulation (EU) 2022/396 of 9 March 2022 implementing Regulation (EU) No 269/2014);
  • It shall be prohibited to sell, supply, transfer or export, directly or indirectly, the goods and technology for maritime navigation listed in Annex XVI, whether or not originating in the Union, to any natural or legal person, entity or body in Russia, for use in Russia or for incorporation on board a Russian flag vessel. Financing and technical assistance related to the following shall also be prohibited (Regulation 2022/394 amending Regulation 833/2014; Art. 3f in connection with Annex XVI).
  • All transactions related to the management of the reserves and assets of the Central Bank of Russia, including transactions with any legal person, entity or body acting on behalf of or at the direction of the Central Bank of Russia, such as the Russian National Property Fund, are prohibited (Regulation 2022/394 amending Regulation 833/2014; Art. 5a(4)).
  • In Article 1f, the term 'transferable securities' shall be supplemented to include crypto assets (Regulation 2022/394 amending Regulation 833/2014; Art. 1f).

 

1 March 2022

  • The following banks are prohibited from providing specialised financial communication services used for the exchange of financial data (SWIFT): Bank Otkritie, Novikombank, Promsvyazbank, Rossiya Bank, Sovcombank, VNESHECONOMBANK (VEB), and VTB BANK. This prohibition shall also apply to any legal person, entity or body established in Russia of which more than 50 % is owned, directly or indirectly, by the banks listed. The exclusion of the listed banks from SWIFT shall take place on 12.3.2022. (Regulation 2022/345 amending Regulation 833/2014).
  • It is prohibited to invest in, participate in or otherwise contribute to projects co-financed by the Russian Direct Investment Fund. (Regulation 2022/345 amending Regulation 833/2014; Art. 2e(2))
  • It is prohibited to sell, supply, transfer or export euro banknotes to Russia or to any natural or legal person, entity or body in Russia, including the Government and the Central Bank of Russia, or for use in Russia (Regulation 2022/345 amending Regulation 833/2014; Art 5i).
  • Prohibition of broadcasting channels: RT – Russia English, RT – Russia Today UK, RT – Russia Today Germany, RT – Russia Today France, RT – Russia Today Spanish in Sputnik (Regulation 2022/350 amending Regulation 833/2014; Art. 2f).

 

28 February 2022

  • Central Bank of Russia: all transactions related to the management of the reserves and assets of the CBR are prohibited, including transactions with any legal person, entity or body acting on behalf of or at the direction of the CBR (Regulation 2022/334 amending Regulation 833/2014);
  • Air transport: Russian air carriers, all aircraft registered in Russia and all aircraft not registered in Russia but owned, leased or otherwise controlled by any Russian natural or legal person, entity or body shall be prohibited from landing in, taking off from or transiting the territory of the Union (Regulation 2022/334 amending Regulation 833/2014).

 

25 February 2022

  • Financial sector: prohibition on of listing and provision of services in relation to shares of Russian state-owned entities on Union trading venues. Prohibition on the acceptance of deposits above certain amounts from Russian citizens or residents, on the maintenance of accounts of Russian clients by central securities depositories in the Union and on the sale of euro-denominated securities to Russian clients (Regulation 2022/328 amending Regulation No 833/2014);
  • Energy and transport sector: prohibition on the sale, supply, transfer or export to Russia of certain goods and technologies for use in the refining of crude oil, and restrictions on the provision of related services; prohibition on exports covering goods and technologies suitable for use in the aerospace industry, and on the provision of insurance, reinsurance and maintenance services in respect of those goods and technologies, prohibition on the provision of technical assistance and other related services, and on the provision of financing and financial assistance in respect of goods and technologies subject to this prohibition (Regulation 2022/328 amending Regulation No 833/2014);
  • Dual-use goods: additional restrictions on the export of dual-use goods and technologies and the provision of related services, as well as restrictions on the export of certain goods and technologies that could contribute to technological improvements in the Russian defence and security sector. It also introduces restrictions on the provision of related services. Limited exemptions from such restrictions are provided for legitimate and predefined purposes (Regulation 2022/328 amending Regulation No 833/2014);
  • Export controls and export financing: prohibition on providing public financing or public financial assistance for trade with or investment in Russia, subject to certain exceptions (Regulation 2022/328 amending Regulation No 833/2014);
  • Additional individuals listed, including Vladimir Putin and Sergei Lavrov, the remaining members of the Russian State Duma who voted in favour of recognition, members of the National Security Council, and individuals who facilitated Russia's military aggression from Belarus (Regulation 2022/328 amending Regulation No 833/2014);
  • New listing criteria (Regulation 2022/330 amending Regulation 269/2014).

 

23 February 2022

  • Listing 336 members of the Russian State Duma who voted in favour of recognising Donetsk and Luhansk (Council Implementing Regulation (EU) 2022/261 of 23 February 2022 implementing Regulation (EU) No 269/2014);
  • Listing of 22 individuals and 4 entities for their actions against the territorial integrity, sovereignty and independence of Ukraine: These include decision-makers, such as members of the government, who participated in illegal decisions; banks and businessmen/oligarchs who financially or materially support or benefit from Russian operations in the territories of Donetsk and Luhansk; senior military officers who participated in the invasion and destabilisation measures; and individuals responsible for waging a war of spreading disinformation against Ukraine (Council Implementing Regulation (EU) 2022/260 of 23 February 2022 implementing Regulation (EU) No 269/2014);
  • Restrictions on economic relations with the non-government-controlled parts of the Donetsk and Luhansk administrative regions (establishment of a new sanctions regime): a ban on the import of goods from the non-government-controlled areas of Donetsk and Luhansk regions, restrictions on trade and investment related to certain sectors of the economy, a ban on the provision of tourist services, and a ban on the export of certain goods and technologies (Council Regulation 2022/263 of 23 February 2022);
  • restrictions on Russia's ability to access EU capital and financial markets and services: prohibition on financing of the Russian Federation, its government and central bank (Council Regulation 2022/262 amending Regulation 833/2014).

 

 

With regard to Russia, the Government of the Republic of Slovenia has adopted the following implementing Regulation: Regulation concerning restrictive measures in connection with Russia's action in connection with the situation in Ukraine and the implementation of regulations (EU) relating to those restrictive measures (Official Gazette, No 34/2022) (pisrs.si).

 

 

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