Since 2014, European Union has progressively imposed sanctions against Russia in response to deliberate destabilization of Ukraine. After February 2022, EU massively expanded the sanctions, which consists of a wide range of financial, economic and trade measures.
The below represent an effort to provide a brief overview of key sanctions which are currently active:
- Restrictions on transactions with major banks and companies in several economic sectors in Russia as well as with transactions with Russian Central Bank (RCB).
- Banning of Russian Nationals entities and bodies in EU public procurement contracts.
- Exclusion from SWIFT system Russian Banks.
- Prohibition to provide credit ratings.
- All funds and economic resources belonging to, owned, held or controlled by any natural or legal persons, entities or bodies and any other associated with them shall be frozen.
- No funds or economic resources shall be made available, directly or indirectly, to or the benefit of natural or legal persons, entities or bodies and any other associated with them.
Restriction of Transportation:
- Closure of the EU airspace
- Closure of the EU ports
- Full prohibition for any Russian road transport undertaking in the EU.
Additional restrictions have been imposed regarding the provision of corporate, legal or other services to Russian nationals and entities of Russian interests.
It shall be prohibited:
- to sell transferable securities denominated in any official currency of a Member State or units in collective investment undertakings providing exposure to such securities, to any Russian national or natural personal residing in Russia or any legal person, entity or body established in Russia. This does not apply to nationals of a Member State or natural persons having a temporary or permanent residence permit in a Member State.
- 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:
(a) Russian nationals or natural persons residing in Russia;
(b) legal persons, entities or bodies established in Russia;
(c) legal persons, entities or bodies whose proprietary rights are directly or indirectly owned for more than 50 % by a natural or legal person, entity or body referred to in points (a) or (b);
(d) legal persons, entities or bodies controlled by a natural or legal person, entity or body referred to in points (a), (b) or (c);
(e) a natural or legal person, entity or body acting on behalf or at the direction of a natural or legal person, entity or body referred to in points (a), (b), (c) or (d).
In 6th of October 2022, European Union adopted the eighth package of sanctions against Russia. The package lays the basis for the required legal framework to implement the oil price cap envisaged by the G7. Also, additional individuals and entities have been sanctioned.
The sanctions, also, 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 and certain elements used in the jewellery industry. Moreover, exports of coal including coking coal, specific electronic components, technical items used in the aviation sector, as well as certain chemicals are being banned.
The 8th sanction package contains prohibitions on the provision of architectural and engineering services, IT consultancy services and legal advisory services to the Government of Russia or any legal persons, entities, or bodies established in Russia.
Regarding the legal services, the prohibition does not extend to representation, advice, the preparation of documents and verification of documents in the context of legal representation services, namely in matters or proceedings before administrative agencies, courts, other duly constituted official tribunals, and arbitral and mediation proceedings. The restrictions cover the provision of legal services in the field of commercial transaction, negotiations and other dealings with third parties and the preparation, execution and verification of legal documents.
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