Member Article

Over the weekend, the EU announced its 10th sanctions package against Russia as a response to the invasion of Ukraine. The timing of the 10th sanctions package coincides with the anniversary for Russian invasion of Ukraine.

The measures implemented in the new sanctions package include, inter alia:

• Additional sanction listings of 121 individuals and entities. Notably, the additions include the three banks Alfa-Bank, Rosbank and Tinkoff Bank as well as the Dubai-based shipping company "SUN Ship Management (D) Ltd.".
• Additional export prohibitions, including an export ban on products such as (but not limited to) vehicles, construction goods, electronics, industrial plants and goods used in the aviation industry and an addition of 96 entities, including 7 Iranian entities, to the list of entities subject to enhanced prohibitions regarding dual-use and advanced technology.
• Additional import bans on Bitumen and related materials like asphalt, and synthetic rubber and carbon blacks.
• A prohibition on transit of dual-use goods and firearms from the EU to third countries through Russia to avoid diversion.
• A ban of two additional Russian media outlets (RT Arabic and Sputnik Arabic).
• A prohibition for Russian nationals to sit in governing bodies in EU member states' critical infrastructure companies,
• A probation for Russian nationals and entities to book gas storage capacity in the EU
• A notification requirement for private flights between the EU and Russia, directly or via third countries. 
• New reporting obligations on frozen assets and assets which should be frozen.
• Technical amendments, such as a new definition on the term "import", meant to help confusion regarding goods "stuck" in customs.

Further to the new sanctions, the EU is working towards ensuring stronger enforcement of the sanctions, e.g. by the convening of the first "Sanction Coordinators Forum" which was held on 23 February 2023.

The deputy chancellor of Germany, Robert Habeck, has expressed that Germany will push for further enforcement proposals in the 11th sanctions package, e.g., by requiring companies to provide "end-use statements" as part of their export declarations to ensure that exported sanctioned goods will not be re-exported to Russia after leaving the EU.

Do you want to know more?

If you need advice relating to the sanctions against Russia or related topics please contact Plesner's Export Control and Trade Sanctions team

Read the Official Journal of the European Union, L 059I, 25 February 2023

Read the press release from the EU Commission dated 25 February regarding the 10th sanctions package

Read the Statement by EU Sanctions Envoy David O'Sullivan on the first Sanctions Coordinators Forum