Update: EU Introduces Its 8th Wide-Ranging Sanctions Package Against Russia

The European Union adopted its 8th sanctions package of restrictive measures against Russia on 6 October 2022 in response to the ongoing conflict in Ukraine.

Further Asset Freeze Restrictions

The European Union has designated a number of additional individuals for asset freeze restrictions:

• Persons involved in Russia's occupation and illegal annexation of areas of Ukraine
• Persons in the defence sector including high-ranking officials of the Russian Ministry of Defence
• Persons who spread disinformation about the war—in particular, those who spread false information and donate funds to Russia-occupied areas

The European Union has already broadened the listing criteria on which specific designations can be based in order to target those who facilitate the circumvention of EU sanctions.

Restrictions on Zaporizhzhia and Kherson

The restrictions that apply to Donetsk and Luhansk have been extended to cover all non-government-controlled areas of Ukraine, including the oblasts of Zaporizhzhia and Kherson.

New Import Bans on Certain Russian Products

The sanctions include an extension of the import ban on steel products and impose new restrictions, including in relation to wood pulp and paper, cigarettes, plastics and finished chemical products such as cosmetics, certain elements used in the jewellery industry, and certain machinery and chemical items.

Additional Export Restrictions

The European Union has sought to further limit Russia’s military, technological enhancement, and defence sector by extending export bans to include products such as the following:

• Additional items used in the aviation sector
• Certain electronic components
• Certain goods, chemical substances, and nerve agents that can be used for capital punishment, torture, or other cruel, inhuman, or degrading treatment or punishment
• Firearms and their parts plus essential components and ammunition

Additional Bans on Providing European Services to Russia

The sanctions package contains prohibitions on the provision of architectural and engineering services, legal advisory services, and IT consultancy services to the Government of Russia or any legal persons, entities, or bodies established in Russia.

EU Nationals Prohibited from Holding Certain Posts

There is a prohibition on EU nationals holding any posts in the governing bodies of certain Russian state-owned or controlled legal persons, entities, or bodies.

Maritime Transport of Crude Oil and Petroleum Products

• There is a derogation from the prohibition to provide maritime transport and the prohibition to provide technical assistance, brokering services, or financing or financial assistance related to the maritime transport to third countries of crude oil or petroleum products that originate in or are exported from Russia, purchased at or below the price cap.
• Further restrictions on maritime transport of crude oil and petroleum products to third countries will be implemented.

Both of these points are conditional on the European Union introducing a price cap.

RMRS

The Russian Maritime Register of Shipping (RMRS) is added to the list of state-owned entities subject to the transaction ban contained in Article 5aa of Regulation (EU) No. 833/2014.

Cryptoassets

The sanctions include a ban on the provision of cryptoasset wallet, account, or custody services to Russian persons and residents regardless of the total value of such cryptoassets.

Notably, the United Kingdom also recently announced that it will introduce additional sanctions on Russia in the near future. The precise form of the new UK restrictions—including the extent to which they might follow the new EU prohibitions—is not yet known.

Ukraine Conflict: How to Maintain Global Business Continuity

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