Tabla de contenidos
The European Union has adopted its 14th package of sanctions against Russia, aiming to exert further pressure amidst ongoing geopolitical tensions. This comprehensive package introduces new measures and updates existing sanctions across various sectors, including energy, finance, transport, and import/export controls. Key elements of the sanctions package are outlined below:
NEW DESIGNATIONS
- Individuals and Entities: The EU has designated 79 individuals and 47 entities. This includes businesspersons, singers, ministers, deputies, governors, oligarchs, ambassadors, CEOs, propagandists, military personnel, judiciary members, FSB operatives. Also, this includes military-industrial companies, notably, Sovcomflot, Russia’s largest shipping company.
For more details, refer to the relevant EU regulation: Council Implementing Regulation (EU) 2024/1746
ENERGY MEASURES
- LNG Transshipment Ban: Prohibits reloading services of Russian LNG (liquefied natural gas) in the EU for transshipment to third countries, with a transition period of 9 months. However, prohibitions are only imposed on the import of Russian LNG through EU terminals not connected to the natural gas system.
- Investment Ban: Prohibits new investments, as well as the provision of goods, technology, and services for completing LNG projects under construction, such as Arctic LNG 2 and Murmansk LNG.
ANTI-CIRCUMVENTION
The provision prohibiting the circumvention of sanctions is amended by extending the knowledge and voluntariness requirements to include those who accept the possibility that their actions may circumvent restrictive measures. By means of:
- Subsidiary Compliance: EU parent companies must ensure third-country subsidiaries do not circumvent sanctions.
- Military Goods Sales: EU entities must implement due diligence to prevent re-exportation of military goods to Russia.
- Industrial Know-How: EU entities must include contractual provisions to prevent the transfer of industrial know-how to Russia.
FINANCE
- Financial Messaging Services: EU entities outside of Russia are prohibited from using the Central Bank of Russia’s financial messaging service and from transactions with listed entities using this service.
- Targeted Financial Institutions: Prohibits transactions with financial institutions and crypto assets providers that support Russia’s defense-industrial base.
- Fixed funds: Introduces an exception for the release of immobilised funds for transfers between non-sanctioned entities, in order to maintain some economic flexibility.
For more details, refer to the relevant EU regulation: Council Regulation (EU) 2024/1739
FUNDING OF POLITICAL PARTIES AND OTHER ORGANISATIONS
- Funding Ban: EU political parties, foundations, NGOs, and think tanks are prohibited from accepting funding from the Russian state.
- Media Activities: Media service providers can continue research and interviews in the EU, but their activities may not be related to broadcasting. In addition, the Council, in order to counter propaganda actions against the European Union by the Russian Federation, has decided to urgently suspend the broadcasting activities of four new media in the Union: Voice of Europe, RIA Novosti, Izvestija, Rossiiskaja Gazeta.
For more details, refer to the relevant EU regulations: Council Decision (CFSP) 2024/1770 and Council Implementig Regulation (EU) 2024/1776
TRANSPORT
- Port Access Ban: Prohibits specified vessels from accessing EU ports and related services, especially those involved in transporting Russian military equipment or circumventing the oil price cap.
- Flight Ban Expansion: Prohibition to land, take off or fly over the territory of the EU shall also apply to any aircraft used for a non-scheduled flight, and where a Russian natural or legal person, entity or body is able to effectively determine the place or time of its take-off or landing.
- Road Transport Ban: Prohibits the transport of goods by road for EU companies owned 25% or more by a Russian individual or entity.
IMPORT/EXPORT CONTROLS
- Export Restrictions: Imposes restrictions on 61 entities supporting Russia’s military and industrial complex, located in various countries, including China and Türkiye.
- Restricted Items List: New restrictions on exports of goods necessary for the improvement of industrial capacities, including chemicals, plastics, machinery, monitors and electrical equipment. Prohibits the import of helium from Russia. Prohibits the import of Ukraine cultural property goods.
- Liechtenstein Partnership: Adds Liechtenstein as a partner country for similar iron and steel restrictions.
PROTECTION OF EU OPERATORS
- Compensation Claims: A provision is introduced to allow nationals and companies of Member States to obtain compensation from Russian entities for sanctions-related damages. Such compensation can be claimed in the courts of the Member States according to the relevant rules.
- Transaction Bans: Authorizes transaction bans on companies interfering with arbitration and court competence.
- Professional secrecy: Information related to the implementation of restrictive measures should be protected by professional secrecy to prevent its disclosure from hampering the effectiveness of such measures. Proposed amendments and related preparatory documents should also receive the same protection to ensure the integrity and effectiveness of future measures.
For more details, refer to the relevant EU regulation: Council Regulation (EU) 2024/1739
INTELLECTUAL PROPERTY RIGHTS RESTRICTIONS
- IP Applications: Restricts certain IP rights registrations by Russian individuals and entities in the EU.
CLARIFICATIONS AND AMENDMENTS ON DIAMOND BAN
- Diamond Ban Clarification: Specifies that the ban does not apply to diamonds located in the EU or a third country before the ban.
- Temporary Imports/Exports: Allows temporary imports or exports of jewelry for trade fairs and repairs.
- Sunrise Period Extension: Extends the sunrise period for full-traceability of diamonds until March 1, 2025.
- Jewelry Ban Postponement: Delays the ban on jewelry incorporating Russian diamonds processed in third countries until further Council action.
For more details, refer to the relevant EU regulations: Council Decision (CFSP) 2024/1738
******
More information:
Lupicinio International Law Firm
C/ Villanueva 29
28001 Madrid
P: +34 91 436 00 90