EU agrees 10th package of sanctions against Russia

On the 25^th February 2023 the European Council adopted the 10^th package of sanctions against Russia. The package contains new listings plus trade and financial sanctions, including further export bans worth more than €11 billion, depriving the Russian economy of critical tech and industrial goods. It also steps up enforcement and anti-circumvention measures, including a new reporting obligation on Russian Central Bank assets.

Specifically, this package contains the following elements:

Additional listings

The EU has added about 121 individuals and entities to the sanction list, including Russian decision-makers, senior government officials and military leaders complicit in the war against Ukraine, as well as proxy authorities installed by Russia in the occupied territories in Ukraine, among others. The list also includes key figures involved in the kidnapping of Ukrainian children to Russia, as well as organisations and individuals, who are polluting the public space with disinformation, adding to the military warfare through information warfare.

Additional EU export bans and restrictions

New export restrictions have been introduced on sensitive dual-use and advanced technologies that contribute to Russia’s military capabilities and technological enhancement. This includes additional electronic components used in Russian weapons systems (drones, missiles, helicopters, other vehicles), as well as bans on specific rare earths and thermal cameras with military applications.

Additional export bans are now also imposed on goods that can be easily redirected to be used to support the Russian war effort including:

• Vehicles: heavy trucks not yet banned (and their spare parts), semi-trailers, and special vehicles such as snowmobiles;
• Goods easily directed to the Russian military: including electric generators, binoculars, radars, compass, etc.;
• Construction goods such as bridges, structures for buildings tower-like, fork-lifts trucks, cranes, etc.;
• Goods that are critical for the functioning and enhancement of Russian industrial capacity (electronics, machine parts, pumps, machinery for working metals, etc.);
• Complete industrial plants: this category has been added to avoid loopholes;
• Goods used in the aviation industry (turbojets).

These new bans and restrictions cover EU exports worth EUR 11.4 billion (2021 data). They come on top of the €32.5 billion worth of exports already sanctioned in the previous packages. With the 10^th package, the EU has sanctioned in total nearly close to half (49%) of its 2021 exports to Russia.

Additional imports ban into the EU

The 10th package imposes import bans on the following Russian high-revenue goods:

• Bitumen and related materials like asphalt; and
• Synthetic rubber and carbon blacks.

These new import bans cover EU imports worth almost EUR 1.3 billion and they come on top of €90 billion already sanctioned, representing altogether 58% of the EU’s 2021 imports.

Financial sector

Three Russian banks have been added to the list of entities subject to the asset freeze and the prohibition to make funds and economic resources available.

Critical infrastructure and gas storage:

• A ban on Russian nationals from serving on governing bodies of Member States’ critical infrastructure companies;
• Prohibition on Russian nationals and entities to book gas storage capacity in the Union (LNG excluded);
• Measures to facilitate the divestment from Russia by EU operators.

A third country shipping company, suspected of helping Russia circumvent sanctions on oil exports, has also been listed.

The 10^th package imposes new reporting obligations on Russian Central Bank assets. This is especially important regarding the possible use of public Russian assets to fund the reconstruction of Ukraine after Russia is defeated.

Anti-circumvention measures:

• Reporting obligations on frozen assets (including for dealings before listings) and assets which should be frozen;
• Private flights between the EU and Russia, directly or via third countries, should be notified in advance;
• Prohibition to transit dual use goods and firearms via the territory of Russia to third countries.

Additional bans on Russian disinformation outlets

Two additional Russian media outlets have been added to the media ban.

Technical amendments

• Amendment to allow the provision of pilot services necessary for maritime safety;
• Definition of the term “import” to avoid goods being “stranded” in long customs procedures.