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.
The European Union has designated a number of additional individuals for asset freeze restrictions:
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.
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.
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.
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:
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.
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.
Both of these points are conditional on the European Union introducing a price cap.
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.
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.
Our lawyers have long been trusted advisers to clients navigating the complex and quickly changing global framework of international sanctions. Because companies must closely monitor evolving government guidance to understand what changes need to be made to their global operations to maintain business continuity, we offer this centralized portal to share our insights and analyses. To receive the latest updates, subscribe to our Ukraine Conflict: How to Maintain Global Business Continuity mailing list.
If you have any questions or would like more information on the issues discussed in this LawFlash, please contact any of the following: