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The ninth package of EU sanctions to the Russian Federation

we hereby inform you that on 16 December 2022, the Council of the European Union adopted the ninth package of sanctions against Russia, in response to the invasion of Ukraine that began last February.

The ninth package of EU sanctions to the Russian Federation

The Council of the European Union adopted EU Regulation No. 2022/2474, which amends EU Regulation No. 833/2014 to introduce further restrictions. The main changes emerging from the new sanctions package are outlined below.

RESTRICTIONS ON GOODS 

With specific regard to the restrictions introduced on imports and exports, the Council of the European Union:

  • expanded the export ban concerning goods and technologies useful to the aviation and space industry set out in Annex XI of EU Regulation 833/2014, now also including aircraft engines and their parts;
  • expanded the list of goods that could contribute to the strengthening of Russia's industrial capabilities to include items such as: generators, toy drones, laptops, hard disks, computer components, night vision and radio-navigation equipment, camera equipment and lenses;
  • clarified the extension of the derogation from the ban on the import of crude oil from Russia granted to Bulgaria: it is now made explicit that this Member State may not sell petroleum products obtained from Russian crude oil imported based on this derogation, to customers located in other Member States or third countries;
  • provided for the prohibition, as of 30 September 2023, of the import or purchase of steel products of Russian origin listed in Annex XVII of Regulation 833/2014; for certain steel products, however, this restriction will apply as of 1 April 2024 or 1 October 2024.

By way of partial derogation from the aforementioned bans, the Council has provided an exception to the commodity restrictions that allows, until 30 September 2023 and subject to prior authorization, the import and export of certain products, provided that this is necessary for divesting or liquidating business activities in Russia.

RESTRICTIONS IN THE FINANCIAL SPHERE

The Council of the European Union has also expanded the prohibition on making new investments in the Russian energy sector, in particular prohibiting new investments in the Russian mining sector, except in the mining and quarrying activities involving certain critical raw materials referred to in Annex X of EU Regulation 2022/2474 (through which a new Annex XXX to EU Regulation 833/2014 is introduced).

RESTRICTIONS ON INDIVIDUALS AND ENTITIES

Finally, the Council designated 49 new entities and 141 new individuals subject to restrictive measures. Notable among these entities is the Russian Regional Development Bank, in respect of which a total ban on transactions is envisaged.

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In order to export goods and products in compliance with the EU regulations as recently amended, we remind you that merely consulting the Annexes to the European Regulations or other black lists is not sufficient, but it is deemed necessary to perform a circumscribed and specific due diligence activity, both objective and subjective.