Today, the EU published the 12th package of sanctions in relation to the invasion of Russia in the Ukraine. The following regulations have been amended:
Ukraine related Decision 2014/145 and Regulation 269/2014:
a) 61 persons/86 entities added;
b) Extending listing criteria benefitting from the transfer of ownership;
c) Setting conditions to retain the name of a deceased person;
d) A derogation to allow for the release of frozen funds;
e) A derogation from the asset freeze in relation to Russian entities where the ownership/control by a EU person/entity has been transferred;
f) Extending the deadline allowing payments by the Jewish Claims Conference;
g) A derogation in relation to the purchase/import/transport of agricultural and food products;
h) A temporary derogation from the asset freeze to allow the sale/transfer of rights in a legal person/entity/body in the Union;
i) A derogation from the asset freeze to allow the termination of contracts with newly listed entities;
j) Technical amendments.
*Note: In our opinion, these measures are amending existing measures, not introducing new measures.
Russia related Decision 2014/512 and Regulation 833/2014:
a) A prohibition on the import of diamonds;
b) 29 entities added to Annex IV;
c) Expanding the list of items which contribute to Russia’s military and technological enhancement or the development of its defence/security sector;
d) A list of partner countries which apply restrictive measures on imports of Iron and a import control measures trat are substantially equivalent to those of the EU;
e) Extending certain wind-down periods for the import of specific steel products;
f) Further restrictions on exports of goods which could contribute to the enhancement of Russian industrial capacities.
g) Further restrictions on imports of goods which generate significant revenues for Russia;
h) Permitting Member States to allow the entry into the Union of certain personal effects;
i) A derogation related to the Russian energy sector;
j) Prolonging imports from Russia of crude oil and petroleum products;
k) A requirement that itemised price information for ancillary costs be shared, in relation to the Price Cap;
l) Notification requirement for the sale of tankers;
m) Extending the exemption for specific projects related to the Price Cap;
n) A ban on Russian nationals or natural persons residing in Russia from owning/controlling/holding posts providing crypto services;
o) Extending the prohibition on the provision of services to include software for the management of enterprises and industrial design and manufacture;
p) Exemptions and derogations regarding the Paks II project for the interests of Hungary;
q) Reporting requirements for the transfer ouf of the Union by entities in the Union owned/controlled by Russians;
r) Requirement for exporters to contractually prohibit re-exportation to Russia or for use in Russia of specific goods;
s) Technical amendments.
*Note: In our opinion, the measures mentioned in a) diamonds, o) further restriction on exports of goods, q) reporting requirements, r) contractual obligations are new measures in relation to the previous restrictive measures of the EU against Russia and therefor do require the implementation of additional measures by companies. Please also make sure to use the annexes of the latest Regulation on top of the last consolidated PDF of 1 October 2023, as long as the EU has not published updated consolidated PDFs.
For a full and correct description, please see the relevant Decisions and Regulations. When you are a subscriber to SanctIO, please keep in mind that when you have a basic subscription, you will not find these changes as the EU has not yet published the consolidated PDFs. When you have a Standard description, you can find the relevant changes in the "view changes".