Client Alert 08 Apr. 2022

EU Publishes Fifth Package of Sanctions Against Russia

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The EU published its fifth package of sanctions against Russia on April 8, 2022. The package contains the following six elements:

Coal ban

  • An import ban on all forms of Russian coal. This affects one fourth of all Russian coal exports, amounting to around €8 billion loss of revenue per year for Russia.

Financial measures

  • A full transaction ban and asset freeze on four Russian banks, which are now totally cut off from the markets.
  • A prohibition on providing high-value crypto-asset services to Russia.
  • A prohibition on providing advice on trusts to wealthy Russians.

Transport

  • A full ban on Russian and Belarusian freight road operators working in the EU. Certain exemptions cover essentials, such as agricultural and food products, humanitarian aid as well as energy.
  • An entry ban on Russian-flagged vessels to EU ports. Exemptions apply for medical, food, energy, and humanitarian purposes, amongst others.

Targeted export bans

  • Further targeted export bans. This includes, for example, quantum computing, advanced semiconductors, sensitive machinery, transportation and chemicals. It also includes specialist catalysts for use in the refinery industry.
  • Adding jet fuel and fuel additives.

Extending import bans

  • Additional import bans – worth €5.5 billion - including cement, rubber products, wood, spirits (including vodka), liquor, high-end seafood (including caviar), and an anti-circumvention measure against potash imports from Belarus.

Excluding Russia from public contracts and European money; legal clarifications and enforcement

  • Full prohibition on the participation of Russian nationals and entities in procurement contracts in the EU. Limited exceptions may be granted by the competent authorities where there is no viable alternative.
  • Restriction on financial and non-financial support to Russian publicly owned or controlled entities under EU, Euratom and Member State programmes (e.g. Horizon 2020).
  • Extending to all official EU currencies the prohibitions on the export of banknotes and on the sale of transferrable securities.

The sanctions package includes listings of 217 additional individuals and 18 entities. In total, 1091 individuals and 80 entities have been sanctioned since 2014.

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