Client Alert 28 Feb. 2024

EU Adopts 13th Package of Sanctions Against Russia

Click here to download the full alert with footnotes.

On February 23, 2024, the EU adopted the 13th package of sanctions against Russia with the occasion of the 2nd year mark of the full-scale invasion.

This package focuses on further limiting Russia's access to military technologies, such as for drones, and on listing additional companies and individuals involved in Russia's war effort. With this new package the number of individual listings has reached over 2000. The key elements of the 13th package are the following:

  • Designations

This is an unprecedented package of 194 individual designations, including 106 individuals and 88 entities. With it, the EU exceeds the threshold of 2000 listings. The designations specifically target:

  • Russia’s military and defense sector (including manufacturers of missiles; drones, anti-aircraft system, military vehicles, high-tech components for weapons and other military equipment);
  • Third country public administrations, corporations and individuals partnering with Russia for the provision of military equipment (the designations target the Defence Minister of the DPRK, as well as several Belarusian companies and individuals);
  • Entities involved in circumvention;
  • Individuals and entities involved in violation of children rights;
  • Authorities from occupied territory: six judges and 10 officials in the occupied territories of Ukraine.

Those designated are subject to an asset freeze and EU citizens and companies are forbidden from making funds available to them. Natural persons are additionally subject to a travel ban, which prevents them from entering or transiting through EU territories.

  • Import-export controls and restrictions

The EU added 27 new entities to the list of those directly supporting Russia’s military and industrial complex in its war of aggression against Ukraine. They are now subject to tighter export restrictions concerning dual use goods and technologies, as well as goods and technology which might contribute to the technological enhancement of Russia’s defence and security sector.

Some of these entities are located in third countries (India, Sri Lanka, China, Serbia, Kazakhstan, Thailand, and Turkey) and have been involved in the circumvention of trade restrictions, others are Russian entities involved in the development, production and supply of electronic components for Russia’s military and industrial complex.

The new sanctions package also expands the list of restricted items that could contribute to the technological enhancement of Russia’s defence and security sector by adding components for the development and production of unmanned aerial vehicles (UAV) such as electric transformers, static converters and inductors as well as aluminum capacitors.

Lastly, the EU introduced further restrictions on exports of goods which contribute in particular to the enhancement of Russian industrial capabilities, such as electrical transformers.

  • Iron & steel

The EU has added the United Kingdom to a list of partner countries which apply a set of restrictive measures on imports of iron and steel from Russia.

Curtis is closely monitoring any legislative development. Curtis is committed to provide the best advice to its clients on how to navigate the complex regulatory environment.

About Curtis

Curtis, Mallet-Prevost, Colt & Mosle LLP is a leading international law firm. Headquartered in New York, Curtis has 19 offices in the United States, Latin America, Europe, the Middle East and Asia. Curtis represents a wide range of clients, including multinational corporations and financial institutions, governments and state-owned companies, money managers, sovereign wealth funds, family-owned businesses, individuals and entrepreneurs.

For more information about Curtis, please visit www.curtis.com.

Attorney advertising. The material contained in this Client Alert is only a general review of the subjects covered and does not constitute legal advice. No legal or business decision should be based on its contents.

Please feel free to contact any of the persons listed if you have questions on this important development.


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