Symbolbild zum 12. Sanktionspaket: Maschine in Fabrik
20.12.2023 | KPMG Law Insights

EU adopts 12th sanctions package against Russia

On December 18, 2023, the Council of the European Union adopted the EU’s 12th sanctions package against Russia. The focus of the new sanctions package is on the introduction of further import and export bans and on combating circumvention measures.

The following changes are particularly noteworthy:

Import ban on Russian diamonds

A new import ban has been introduced for diamonds and products containing diamonds if they originate in Russia or have been exported from Russia to the Union or a third country. Industrial diamonds are exempt from this ban. This ban will gradually be extended to Russian diamonds polished in third countries and to laboratory diamonds and jewelry and watches set with diamonds.

New measures to enforce the oil price cap

In order to enforce the oil price cap, the EU has adopted new measures to monitor tankers more strictly. According to the new Article 3n of Regulation (EU) No 833/2014, the Commission and the Member States shall regularly exchange information in order to identify vessels and organizations engaged in one or more deceptive practices in the transport of Russian crude oil and petroleum products.

Import ban on liquid gas

Furthermore, various forms of liquefied natural gas have been added to the list of goods that generate significant revenues for Russia. In future, the purchase of liquid gas in various forms from Russia will also be prohibited. Contracts concluded before December 19, 2023, may, however, be closed until December 20, 2024 must be fulfilled.

Measures to make circumvention transactions more difficult

The EU has taken various new measures to make it even more difficult to circumvent the existing restrictions:

The transit through Russia of goods listed in Annex XXVII of Regulation (EU) No. 833/2014, which could contribute in particular to strengthening Russia’s industrial capacities, is now prohibited, even if they are intended for export to a third country.

To prevent certain goods, such as electronic components, firearms and aviation goods, from reaching Russia, it must be noted that from March 20, 2024 Anyone exporting these goods from the EU to a third country must contractually prohibit their contractual partners from re-exporting the goods to Russia and from re-exporting the goods for use in Russia.

From May 1, 2024, companies based in the EU that are more than 40 percent dependent on

  • legal entity, organization or institution established in Russia, or
  • a Russian national or
  • a natural person resident in Russia

report to the competent authorities all transfers of funds of more than EUR 100,000 from the Union that they have made directly or indirectly in the context of one or more operations.

Further information on the content of the EU’s 12th sanctions package against Russia can be found in the European Commission’s press release.

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