Sanctions against Russia : recent developments (18 October updates)

 

EU Adopts New Package of Sanctions Targeting Russia

On 6 October 2022 Council of the European Union adopted an eighth package of sanctions targeting Russia following the recent actions attempted by the Russian Government as part of the special military operation in Ukraine. Besides the extension of the personal sanctions list, EU introduced the following sectoral measures:

Exports

Firearms. Ban to sell firearms and their essential parts, components, and ammunition to persons in Russia or for the use in Russia. Provision of related services is also banned.
Aviation. Restrictions related to the export of goods and technology for the use in aviation have been eased. Namely, now restrictions concerning certain goods will not apply to agreements until 6 November 2022 (previously the deadline was 28 March 2022).

Imports

► Steel products. As of 30 September 2023 it becomes prohibited to import or purchase certain listed iron and steel products when processed in a third country incorporating steel products originating in Russia.

  • Crypto-asset restrictions. It is now prohibited to provide crypto-asset wallet, account or custody services to Russian nationals or natural persons residing in Russia, or legal persons, entities or bodies established in Russia. Previous restriction covered only amounts exceeding EUR 10 000.
  • Oil restrictions. New measures provide for a framework allowing to introduce a price cap related to the maritime transport of Russian oil for third countries and further restrictions on the maritime transport of crude oil and petroleum products to third countries. The price cap is yet to be defined.
  • Restrictions targeting state-owned companies. New measures prohibit to hold any posts in the governing bodies of listed legal entities established in Russia which are publically owned or controlled.
  • Restrictions targeting consultancy, IT, financial and other services. It becomes prohibited to provide, directly or indirectly, accounting, auditing, including statutory audit, bookkeeping or tax consulting services, or business and management consulting or public relations services to the Russian Government and legal persons established in Russia.

It is also prohibited to provide, directly or indirectly, architectural and engineering services, legal advisory services and IT consultancy services to to the Russian Government and legal persons established in Russia.

Exceptions to these bans include:

  • Provision of services necessary for termination of said contracts;
  • Provision of services that are strictly necessary for the exercise of the right of defence in judicial proceedings and the right to an effective legal remedy
  • Provision of services which are strictly necessary to ensure access to judicial, administrative or arbitral proceedings in a Member State,

Provision of services intended for the exclusive use of legal persons, entities or bodies established in Russia that are owned by, or solely or jointly controlled by, a legal person, entity or body which is incorporated or constituted under the law of a Member State, a country member of the European Economic Area, Switzerland or a partner country.

 

We are actively following the developments related to those issues  and are fully prepared to advise our clients.

Our last newsletters

Sanctions against Russia. Recent developments (2 march 2023 update)

By the end of February, the EU, US and UK announced new rounds of sanctions, all of them including restrictions targeting prominent Russian financial institutions The EU package includes individual listings of Russian entities and individuals and additional exports restrictions. The US sanctions provide for sectoral sanctions targeting Russian mining and metals sector, as well […]

Moscow Desk

+

Russian counter measures. Recent developments ( 12 january 2023 update)

Governmental Commission on Foreign Investments revised rules on the sale of assets and the payment of dividends On 30 December 2022, Russian Governmental Subcommission of the Commission of the Ministry of Finance on Foreign Investments (the – Commission) published revised rules and criteria for authorization of the sale of assets in Russian companies involving persons […]

Moscow Desk

+

Sanctions against Russia. Recent Developments (21 December 2022 update)

This December, the EU introduced a series of restrictive measures targeting Russia. Council of the EU approved the ninth package of sanctions. Additionally, the European Commission proposed framework that would amend the Lisbon Treaty and harmonize criminalization of violation of sanctions at the level of the Union. Finally, the EU introduced a price cap for […]

Moscow Desk

+

Russian counter measures. Recent developments (21 December 2022 update)

Russia has adopted a series of new measures. Namely, the President introduced new restrictions concerning certain transactions involving credit organizations and joint-stock companies that are not credit organizations. The Russian Central Bank issued decision expanding the scope of application of type C accounts. Moreover, the Ministry of Finance issued clarifications on the scope of transactions […]

Moscow Desk

+

Sanctions against Russia : recent developments (18 October updates)

EU Adopts New Package of Sanctions Targeting Russia On 6 October 2022 Council of the European Union adopted an eighth package of sanctions targeting Russia following the recent actions attempted by the Russian Government as part of the special military operation in Ukraine. Besides the extension of the personal sanctions list, EU introduced the following […]

+

Russian counter measures. Recent developments (29 september 2022 update)

Procedure for the Approval of Transactions with Shares in a Russian LLC Adopted On 19 September 2022 Russian Government introduced amendments establishing a procedure for approval of transactions involving shares in Russian limited liability companies. Such transactions are considered as controlled operations and are to be approved by the Governmental Commission for the Control of […]

Moscow Desk

+

Sanctions against russia. Recent revelopments (13 september update)

CONTROL OF TRANSACTIONS WITH SHARES IN AN LLC On 8 September 2022, Russian President issued Decree No. 618 “On Special Procedure for Execution of Certain Transactions (Operations)” (the “Decree”). The decree provides for new rules, specifically for transactions involving transfer of shares in Russian LLCs as well as transactions involving Russian banks under sanctions.  We […]

Moscow Desk

+

Russian counter measures. Recent Developments (19 August 2022 update)

Russia has adopted a series of new measures. Namely, the President introduced new restrictions concerning transactions with shares in certain Russian companies. The Government added new jurisdictions to the list of unfriendly states. At the same time, the Russian Central Bank suspended some of its previously adopted restrictions. For more information on sanctions targeting Russia, […]

Moscow Desk

+

Sanctions against Russia. Recent Developments (9 August update)

On 21 July 2022, Council of the EU adopted a seventh package of sanctions targeting Russia. The new package establishes new bans and exemptions for sectoral sanctions. It also targets new persons and entities, including Sberbank. Additionally, the US expanded their individual sanctions. Below is an overview of the latest sanctions. For more information on […]

Moscow Desk

+

Russian counter measures : recent developments (update July 12, 2022)

Russia has adopted a series of new measures. Namely, the President and the Government introduced new measures that mainly facilitate operations involving foreign currency. Laws on legalization of parallel importation and on additional powers of the President became effective. Certain legal initiatives were rejected or put on hold. Specifically, the review of the draft law […]

Paris, Moscow Desk

+