In brief, the main new restrictive measures imposed on Russia:
Listings
Who is targeted?
120 individuals and 96 entities added to the sanctions list, including Russian decision-makers, senior government officials, military leaders complicit in the war against Ukraine, as well as proxy authorities installed by Russia in the occupied territories in Ukraine, amongst 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.
Measures are also taken against individuals in Iran who are involved in the elaboration of drones and components supporting Russia’s military. In addition, members and supporters of Russia’s Wagner mercenary group and its activities in other countries, such as Mali or Central African Republic, are also targeted.
Financial sector
Three additional Russian banks have been sanctioned (asset freeze). The listing has a deep impact on the day-to-day business of listed banks, cutting them off from the EU economy and financial system.
Import and export restrictions
What new import and export restrictions have been introduced?
With the 10th package of sanctions against Russia, the EU has introduced new measures concerning both export (value of export bans EUR 11.4 billion) and import (value of import bans EUR 1.3 billion).
On the export side, EU have continued to target goods and technologies particularly relevant for the Russian military and industrial complex and, on the import side, goods that generate significant revenue for Russia.
Additional trade bans on imports into the EU of Russian synthetic rubber and asphalt or bitumen (an oil product) and on exports into Russia of EU industrial goods and goods that can be easily redirected to be used to support the Russian war effort including trucks, other heavy vehicles, construction machines, pumps and other machines used in the construction sector.
The package also includes additional export restrictions on sensitive dual-use and advanced technology items that could contribute to Russia’s military capabilities and technological enhancement, based on information retrieved from Russian military systems on the battlefield. Moreover, the EU are also listing 96 additional entities associated to Russia’s military-industrial complex, bringing the total of military end-users that are listed to 506. This includes for the first time seven Iranian entities that have been using EU components and providing Russia with military “Shahed” drones to attack civilian infrastructure in Ukraine. This should act as a strong deterrent to other companies and international traders that circumvention of export restrictions will not be tolerated. Importantly, we are working in close coordination with partners and are adding Australia, Canada and New Zealand and Norway to the list of our partner countries.
A third country shipping company, suspected of helping Russia circumvent sanctions on oil exports, has also been listed.
What other trade-related measures are included in this package?
Furthermore, a new full export ban is placed on turbojets and their parts, therefore reinforcing the existing ban on aircrafts, their engines and parts.
Anti-circumvention measures
The EU have introduced a transit ban for dual-use goods and advanced technology and firearms via the Russian territory. This means that goods can no longer transit via the territory of Russia when exported to third countries.
Disinformation
Why has the EU added further outlets to the sanctions list?
The EU has added Arab language subsidiaries of RT (Russia Today) and Sputnik because they are Russian state-owned and/or under the Kremlin’s influence and they disseminate disinformation and war propaganda of the sanctioned regime, aiding Russia’s war efforts.
Clarifications
Which clarifications did the EU introduce?
The EU has clarified when and under which conditions, goods can be considered as imported into the Union when such goods were physically in the Union and already presented to customs authorities when they become subject to import restrictions. Such a clarification was necessary for Union operators which brought those goods into the Union in good faith at a time when they were not yet subject to any import restrictive measures.
Reporting obligations
What reporting obligations have been proposed and why?
The new measures introduced the following changes to the reporting obligations:
In Regulation 269/2014 (asset freeze), more detailed reporting obligations on frozen assets (including for dealings before listings) and assets which should be frozen. Operators are required to report this information to Member States, which in turn are required to report it to the Commission.
Central securities depositories report to Member States and also directly to the Commission to streamline the reporting process at EU-level.
These changes, including further details on what information should be provided, are aimed at ensuring a uniform application of the asset freeze provisions.
In Regulation 833/2014 (sectoral sanctions), new reporting obligations for the operators to the Member States and the Commission on assets and reserves of the Central Bank of Russia, which they hold or control or are a counter-party to.
These changes are aimed at ensuring a uniform application of the prohibition of transactions related to the management of reserves and assets of the Central Bank of Russia.
Under the new provisions, Member States and EU operators will have to cooperate with the Commission in the verification of the information provided and the Commission may request any additional information
