28.02.2023 | KPMG Law Insights

EU adopts tenth sanctions package against Russia

In view of the fighting in Ukraine, which has now been going on for about a year, the EU has issued what is now the tenth package of sanctions against Russia. This includes, among other things, an extension of existing export and import restrictions and an extension of existing financial sanctions (asset freeze) to an additional 87 individuals and 34 entities. The transit of dual-use goods to third countries through Russian territory was also banned.
The following is a brief overview of the new restrictions created by the Tenth Sanctions Package.

Expansion of export and import restrictions

With the tenth sanctions package, the EU is extending existing export restrictions to electronic components, special vehicles, machine parts, spare parts for trucks and engines, and goods for the construction sector that may be intended for the Russian military, such as antennas or cranes. Also now covered are new electronic components used in Russian weapons systems, including drones, missiles and helicopters, as well as certain rare earths, electronic integrated circuits and thermal imaging devices.

In addition, with the tenth sanctions package, imports of bitumen, asphalt, carbon and synthetic rubber from Russia are now subject to restrictions.
For companies with export and import business with Russia, this means that a comparison with the updated lists of goods must take place and import or export business with Russia must be stopped with regard to these goods.

Expansion of financial sanctions (asset freeze).

The assets of another 87 individuals and 34 organizations are frozen. These include three other major Russian banks and representatives of the Iranian defense sector.
As a result, companies with payment transactions or goods deliveries to Russia or Iran must ensure that their sanctions list screening is up to date. In particular, due to the inclusion of additional banks on the sanctions list, not only the direct payment recipients or contractual partners but also their credit institutions used for payment processing are to be included in this review.

Measures to prevent the evasion of sanctions

In addition to the above-mentioned restrictions, the EU has also taken various measures aimed at preventing circumvention of the existing sanctions:

Thus, in addition to the sale, supply, transfer or export of dual-use items to Russia, the transit of these items through the territory of Russia is now also subject to a ban. For companies trading in dual-use goods, this means that they will have to adjust their transport routes so that there is no transit of these goods through Russian territory.

Complementing the expansion of existing financial sanctions, information requirements for EU banks and EU companies as well as EU citizens on the assets of sanctioned individuals and companies in the EU and on assets held by the Central Bank of Russia will be expanded. Thus, in the future, information identifying the sanctioned person (including name, address and tax identification number), amount or market value of funds and economic resources, type of funds, amount, location and other relevant characteristics of funds or economic resources must be reported to the competent authority of the Member State in which the information holder:in question is domiciled or resident within two weeks of receiving such information. This is also intended to make it more difficult to circumvent the sanctions imposed by the EU and to make it easier for the competent authorities to locate sanctioned assets.

In the future, aircraft operators will have to notify charter flights at least 48 hours before the flight to their national competent authority, which will then inform the other member states. This is to prevent circumvention of the airspace closure for Russian aircraft in the EU.

Further measures

Two Russian state media are banned from broadcasting. In addition, it is now prohibited to allow Russian citizens and natural persons residing in Russia to hold positions in the governing bodies of the owners or operators of critical infrastructure. It will also be prohibited in the future to provide gas storage capacity in the EU to Russian nationals, Russian residents and Russian companies.

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