European sanctions-general
The EU has been imposing sanctions and restrictive measures against Russia since 2014 following their invasion of Crimea. This European Council infographic provides an excellent summary of the types of sanctions imposed and see also further information here. A useful list which contains summaries of all EU sanctions is available on the EU Sanctions Map.
Click here for a timeline - EU sanctions against Russia produced by the European Council.
Thirteen packages of sanctions (including a maintenance and alignment package) have been adopted to date, the thirteenth package was adopted on 23 February 2024. Also of interest is the list of common high priority items which the EU and its international partners has drawn up to which businesses should apply particular due diligence and which third countries must not re-export to Russia.
In addition, in May 2024 sanctions against disinformation and war propaganda were adopted by the EU. The EU Council suspended the broadcasting activities of four more media outlets (Voice of Europe, RIA Novosti, Izvestia and Rossiyskaya Gazeta) in the EU or directed at the EU, in view of their role supporting and justifying Russia's war of aggression against Ukraine.
On May 27, 2024 the EU adopted a new sanctions regime in relation to deemed human rights violations and internal repression in Russia. It includes export restrictions and the designation of individuals, making them subject to a travel ban and asset freezes. The regime is separate from the EU's Russia-related sanctions in relation to the invasion of Ukraine and it supplements the EU's Global Human Rights sanctions regime. Click here for a press release giving more details of the measures.
Also in May 2024 the EU adopted a new sanctions directive which will harmonise criminal offences for violation of EU sanctions. Please click here for an Institute news item on the new directive.
The European Commission has a dedicated webpage, entitled Sanctions adopted following Russia’s military aggression against Ukraine, which contains information on the various sanctions adopted, including Frequently Asked Questions. The page is regularly updated and the FAQs are divided into the following headings which can be accessed here. See the picture tiles on the page.
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Individual financial measures
Finance and banking
Trade and customs
Energy
Agricultural products
Sector specific questions
The latest FAQs on assets freeze and prohibition on providing funds or economic resources can be accessed here.
Readers may find interesting the European Commission’s podcasts including episode one on sanctions of May 2022 with guest Alina Nedea Head of Sanctions Unit, DG FISMA at European Commission and one of 15 January 2024 entitled "The one about how sanctions are indeed working".
The EU list of sanctions is available on the Irish Central Bank’s website Financial Sanctions Updates . The situation is very fast moving and members are reminded to check these on a frequent basis.
There is a consolidated list of persons, groups and entities subject to EU financial sanctions, which reflects the officially adopted texts published in the Official Journal of the EU. You need to create an account to log in. This is a simple process. EU Login (europa.eu). A PDF version of the consolidated list of financial sanctions can also be downloaded, but members should be aware that this list is constantly being amended and updated..
Please see here European External Action Service website which has some articles and information on sanctions. See also the European Commission page containing general FAQs and answers on restrictive measures - sanctions e.g. types of sanctions and who is bound by them (Click here for the pdf version).
The European Commission has issued Guidance to the Member States concerning foreign direct investment from Russia and Belarus in view of the military aggression against Ukraine and the restrictive measures laid down in recent Council Regulations on sanctions. Download the guidance by following this link.
European Union whistleblower tool
The European Union sanctions whistleblower tool is accessible via the Commission’s website at https://eusanctions.integrityline.com/. It facilitates the anonymous reporting of possible violations of EU sanctions. It can be used to report past, ongoing or planned sanctions violations, as well as attempts to circumvent EU sanctions.
More details about the tool are available at https://ec.europa.eu/info/business-economy-euro/banking-and-finance/international-relations/restrictive-measures-sanctions_en#whistleblower
The various packages of measures in response to Russia's invasion of Ukraine
Thirteenth package February 2024
This package includes the designation of additional companies and individuals involved in Russia's war effort. In addition, the package expands the list of advanced technology items that may contribute to Russia's military and technological enhancement or to the development of its defence and security sector. This includes for example the addition of components used for the development and production of drones. The new package adds the United Kingdom to the list of partner countries for the iron and steel imports. These partner countries apply a set of restrictive measures on imports of iron and steel and a set of import control measures that are substantially equivalent to those in EU Regulation (EU) No 833/2014.
Click here to access further information and to download the press release on the 13th package from the European Commission.
Twelfth package December 2023
The EU adopted a twelfth package of sanctions on 18 December 2023.Please see attached press release providing details .
Some of the measures include a new obligation to contractually prohibit re-exportation of sensitive goods to Russia. Exporters will be required to contractually prohibit the re-exportation to Russia and re-exportation for use in Russia when selling, supplying, transferring or exporting to a third country (with certain exceptions) goods or technology such as aviation and space items, jet fuel and additives and firearms and other arms and ammunition.
Other measures include financial restrictions such as a ban on Russian nationals owning, controlling or holding any posts on the governing bodies of those providing crypto-asset wallet, account or custody services to Russian persons and residents. The existing prohibition on the provision of services will be extended to include a ban on the provision of software for the management of enterprises and software for industrial design and manufacture.
A new measure is introduced that will require the notification of certain transfers of funds out of the EU from EU entities directly or indirectly owned by more than 40% by Russians or entities established in Russia.
Member States must designate by October 31, 2024, a national authority to identify and trace funds and economic resources belonging to, or owned, held, or controlled by designated individuals and entities located in their jurisdiction, to prevent and detect attempts or instances of sanctions violations or circumvention.
Click here for Q&A from the European Commission on the twelfth package and here to see the consolidated FAQs from the European Commission.
Eleventh package June 2023
The latest, 11th EU sanctions package was implemented on 23 June 2023. Click here and here for the press releases from the EU Council. The package introduces further trade, transport and energy restrictions. It also lists over 100 additional individuals and entities subject to asset freezes and other restrictions such as extension of the media ban to 5 additional channels. Click here for a summary of the key elements.
Click here to go to the European Commission website where readers can find further information on the eleventh package including Q&A on the package.
The European Union External Action webpage has a booklet on their website summarising the provisions of the eleventh package which you can access here.
Tenth package February 2023
On 23 February 2023 the Council of the European adopted its tenth package of sanctions against Russia. You can read more details on the tenth package on the European Commission website here a press release on the tenth package here and Questions and Answers: tenth package of restrictive measures against Russia here.
Ninth package -December 2022
On 16 December 2022 the EU adopted its 9th package of economic and individual sanctions.
It includes
-the imposition of export controls and restrictions. New export controls and restrictions on dual-use goods and technology as well as goods and technology that can contribute to the technological enhancement of Russia’s defence and security sector. The sanctions also expand the export ban on aviation and the space industry related goods and technology to include aircraft engines and their parts.
-restrictions in the banking sector
an asset freeze against two additional Russian banks and the addition of the Russian Regional Development Bank to the list of Russian State-owned or controlled entities that are subject to a full transaction ban.
-restrictions in the broadcasting sector
suspension of the broadcasting licences of four additional media outlets: NTV/NTV Mir, Rossiya 1, REN TV and Pervyi Kanal.
-Consulting services
A ban is imposed on the provision of EU advertising, market research and public opinion polling services, as well as product testing and technical inspection services to the Russian Federation.
-Energy and mining sectors
The EU will expand the prohibition targeting new investments in the Russian energy sector by additionally prohibiting new investments in the Russian mining sector, with the exception of mining and quarrying activities involving certain critical raw materials.
Others
EU nationals are forbidden from holding any posts on the governing bodies of all Russian State-owned or controlled legal persons, entities or bodies located in Russia.
Individual listings
In addition to economic sanctions, the EU has added almost 200 additional individuals and entities to the list of persons subject to a freezing of their assets.
Click this page and scroll down to the information on the 9th package including a press release on the 9th package, the 9th package in the official journal and Q&A on the 9th package.
Eighth package-6 October 2022
- Additional listings: Additional individuals and entities have been sanctioned.
- Geographical scope of the restrictive measures has been extended to cover all the non-government-controlled areas of Ukraine and now includes Zaporizhzhia and Kherson.
- New export restrictions: Additional export restrictions have been introduced which aim to reduce Russia's access to military, industrial and technological items, as well as its ability to develop its defence and security sector. This includes the banning of the export of coal including coking coal (which is used in Russian industrial plants), specific electronic components (found in Russian weapons), technical items used in the aviation sector, as well as certain chemicals. A prohibition on exporting small arms and other goods under the anti-torture Regulation has been added.
- New import restrictions: Almost €7 billion worth of additional import restrictions have been agreed.
- Implementing the G7 oil price cap: The eighth package marks the beginning of the implementation within the EU of the G7 agreement on Russian oil exports. While the EU's ban on importing Russian seaborne crude oil fully remains, the price cap, once implemented, would allow European operators to undertake and support the transport of Russian oil to third countries, provided its price remains under a pre-set “cap”. This will help to further reduce Russia's revenues, while keeping global energy markets stable through continued supplies. It would take effect after 5 December 2022 for crude and 5 February 2023 for refined petroleum products, after a further decision by the Council.
- Restrictions on State-owned enterprises: The eighth package bans EU nationals from holding posts in the governing bodies of certain state-owned enterprises.
- It also bans all transactions with the Russian Maritime Register, adding it to the list of state-owned enterprises which are subject to a transaction ban.
- Financial, IT consultancy and other business services: The existing prohibitions on crypto assets have been tightened by banning all crypto-asset wallets, accounts, or custody services, to Russian persons or residents irrespective of the amount of the wallet (previously up to €10,000 was allowed).
- The package widens the scope of services that can no longer be provided to the government of Russia or legal persons established in Russia: these now include IT consultancy, legal advisory, architecture and engineering services. These are significant as they will potentially weaken Russia's industrial capacity because it is highly dependent on importing these services.
- Deterring sanctions circumvention: The EU has introduced a new listing criterion, which will allow it to sanction persons who facilitate the infringements of the prohibition against circumvention of sanctions.
Click here for an article by Clyde & Co LLP on the eighth package.
On 28 September 2022 the EU President von der Leyen issued a press statement on a new eighth package of restrictive measures against Russia. Details on the press release can be found by following the above link. Please click here also for an analysis of the proposals in relation to the eighth package by Herbert Smith Freehills LLP.
The “maintenance and alignment” package:
On 21 July 2022 the EU Council adopted a package of measures in response to Russia's invasion of Ukraine. These new measures are intended to tighten existing economic sanctions targeting Russia, perfect their implementation and strengthen their effectiveness.
Russian gold: This introduces a new prohibition on purchase, import or transfer of Russian-origin gold, including jewellery from 22 July 2022 onwards.
Defence and security exports: The package reinforces export controls of dual use goods. It extends the list of controlled items, which may contribute to Russia’s military and technological enhancement or the development of its defence and security sector, thereby reinforcing export controls on dual use and advanced technology. An additional 51 items have been added to the export control list, mostly from the industrial and advanced technology sectors; including manufacturing equipment such as machine tools that can be used to produce industrial components or weapons, and other items, such as those used for law enforcement, such as helmets and batons, or chemicals used in riot control.
Port access ban extended: the existing port access ban is extended to locks. It provides clarification that Russian ships cannot dock at canal locks in order to circumvent the ban on entering EU ports;
The EU is also introducing a number of clarifications to existing measures, for instance in the field of public procurement, aviation and justice. For instance, the prohibition to enter into any transactions with Russian public entities will be slightly amended to ensure access to justice.
Imposition of restrictive measures on an additional 54 individuals and 10 entities, including the mayor of Moscow Sberbank, a major financial institution and Credit Bank of Moscow (which are already removed from SWIFT messaging system);
The acceptance of deposits of €100,000 from any Russia national/resident, or Russian/Russian resident controlled (50% or more) entity or body from anywhere outside the EU, is now prohibited.
Prior authorisation is required for accepting deposits needed when trading non-prohibited items between the EU and Russia.
In addition to this package, new restrictive measures have also been introduced against military forces that have been aiding (directly and indirectly) the military actions of Russia in Ukraine. These measures add 6 Syrian individuals and 1 Syrian entity to an asset freeze and travel ban list.
New measures, just like earlier sanctions, do not target Russia's exports of food, grain or fertilisers.
Please see here for an EU Q & A on the maintenance and alignment package.
Sixth package of EU Sanctions-June 2022
On 3 June 2022 the European Commission issued a press release announcing adoption of the sixth package of sanctions against Russia. This package also imposes further sanctions against Belarus considering its involvement in the aggression.
This 6th package of measures include:
• A ban on the provision of insurance or reinsurance to the maritime transport of Russian oil to third countries;
• A ban on providing certain business relevant services-directly or indirectly -such as accounting, auditing, including statutory audit, bookkeeping and tax consulting services, business and management consulting and public relations services to the Government of Russia as well as to legal persons entities or bodies established in Russia;
A wide variety of chemicals, including items used as precursors to the creation of chemical weapons, will be banned from sale to Russia;
• The import of goods such as wood, rubber, cement, fertilizer and ingredients used to manufacture fertilizer from Russia and Belarus is banned;
• 65 additional Russian individuals and 18 entities have been made subject to asset freezes and travel bans;
• 12 Belarusian individuals and 8 entities have been made subject to asset freezes and travel bans;
• 3 Russian banks: Sberbank, Credit Bank of Moscow and JSC Rosselkhozbank; and 1 Belarusian bank: Belinvestbank, are removed from SWIFT;
• 3 additional Russian TV stations are subject to a broadcast ban - Rossiya RTR/RTR Planeta, Russia 24 and TV Centre International; and
• RT and Sputnik will also be subject to an advertising ban;
A general prohibition has been introduced on the import and transport of Russian crude oil and petrol products for all EU Member States. A lead-in period of six months has been provided for crude oil and eight months for petrol products, after which the import of such products will be prohibited. Some member states have received derogations from this measure due to their geographic location or their over-reliance on Russian fuel.
Trusts
The fifth package of sanctions adopted a prohibition on providing advice on trusts to wealthy Russians. Following discussions with the EU Commission and discussions amongst Member States, agreement was reached to amend that measure. The position is now that certain types of trust, detailed below, can apply to the competent authorities for a derogation from the sanction. The Dept of Finance information advised that trusts will have 30 days from 3 June 2022 to make such an application. The three Irish competent authorities are the Department of Foreign Affairs, Department of Enterprise, Trade & Employment and the Central Bank of Ireland. There was no information about which (or if all three) competent authority would provide the application facility for trusts; nor was there information about what information a trust would have to provide in order to successfully secure a derogation. The trust types eligible for a derogation are:
• occupational pension schemes;
• insurance policies;
• employee share schemes;
• charities;
• amateur sports clubs;
• funds for minors or vulnerable adults.
In addition, trustees and TCSPs were given an additional month - to 5 July 2022 - to cease all operations with trusts that remain within the remit of the sanction. Please also click the link to read FAQs on the sanction on provision of trust services dated 8 July 2022.
Please see here for a Q&A on the sixth package of sanctions.
On 21 April 2022 the EU adopted restrictive measures against two further individuals within the existing sanctions framework .EU restrictive measures regarding the undermining of territorial integrity of Ukraine now apply to a total of 1093 persons and 80 entities.
Fifth package of EU Sanctions-April 2022
On 8 April 2022 the EU adopted a fifth package of restrictive measures against Russia. The package contains the following six elements (summarised from the information available on the European Commission website and information made available to us from the Dept. of Finance):
1. A coal ban. An import ban on all forms of Russian coal from 10 August 2022.
2. Financial measures
- A full transaction ban and asset freeze on four Russian banks These four banks will now be fully excluded from the EU market. The banks affected are Otkritie, Novikombank, Sovkombank and VTB.
- A prohibition on providing high-value crypto-asset services to Russia.
- A prohibition on being a beneficiary ,acting as a trustee or in similar capacities for Russian persons and entities as well as a prohibition on providing certain services to trusts has been introduced.(You can read some more information about this here).
3. Transport
- A full ban on Russian and Belarusian freight road operators working in the EU. Certain exemptions will cover essentials, such as agricultural and food products, humanitarian aid as well as energy.
- An entry ban on Russian-flagged vessels to EU ports.This includes yachts and recreational craft. Exemptions apply for medical, food, energy, and humanitarian purposes, amongst others.
4. Targeted export bans. Worth €10 billion in areas in which Russia is vulnerable due to its high dependency on EU supplies including for example sensitive machinery, transportation and chemicals. Jet fuel and fuel additives which may be used by the Russian army, are added to the existing export ban.
5. 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.
6.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.
- Addressing various overlaps between export restrictions on dual-use items and advanced technologies and other provisions.
- Extending to all official EU currencies the prohibitions on the export of banknotes and on the sale of transferrable securities.
An additional 217 individuals who are Russian, members of 'the People’s Council' of the Donetsk and Luhansk breakaway republics and 18 entities have been sanctioned.
Please see here for a Q & A on the fifth package .of restrictive measures against Russia .
Fourth package of EU Sanctions-March 2022
On 15 March 2022 the EU published a further set of measures in relation to Russia. The measures that came into force on 15 March include adding another 15 individuals and 9 entities to the list of those subject to asset freezes and travel bans.
The measures that came into force on 16 March include:
- a ban on credit ratings agencies from providing ratings on Russian Federation debt.
- further trade restrictions concerning iron and steel, as well as luxury goods;
- expanding the list of persons connected to Russia’s defense and industrial base, to apply tighter export restrictions on dual-use goods and technology. A total of 81 persons and entities have been added;
- prohibitions on new investments in the Russian energy sector and export restrictions on related equipment, technology and services, with the exception of nuclear industry and energy transport;
- a ban on all transactions with certain State-owned enterprises which are already subject to refinancing restrictions. A total of 13 companies are listed;
- a ban on the provision of insurance and reinsurance to any legal person, entity or body operating in the energy sector in Russia;
- Derogations have been provided for activities necessary for ensuring critical energy supply within the EU, as well as the transport of fossil fuels, in particular coal, oil and natural gas, from or through Russia into the EU; and where humanitarian considerations arise.
Please see
here a Q &A from the European Commission website on the fourth package of restrictive measures against Russia.
On 9 March 2022, the European Council issued a press release announcing the EU's agreement to new sectoral measures targeting Belarus and Russia, this one targeting the Belarusian financial sector and a further press release later the same day concerning its decision to impose restrictive measures on 160 individuals as a consequence of Russia’s military aggression against Ukraine.
Details of measures introduced on 9 March 2022 include:
Introduction of further restrictions on the export of maritime navigation goods and technology;
- Expansion of the list of legal persons, entities and bodies subject to the prohibitions related to investment services, transferable securities, money market instruments, and loans;
- Further clarification (in respect of previous restrictive measures) that “transferable securities” includes crypto-assets.
- Limiting the financial inflows from Belarus to the Union, by prohibiting the acceptance, from Belarusian nationals or residents, of deposits exceeding certain values; the holding of accounts of Belarusian clients by the Union central securities depositories; and the selling of euro-denominated securities to Belarusian clients;
- Exemptions under the sanctions measures, for Swiss, EU and EEA nationals in Belarus, in that deposits exceeding €100,000 can be accepted from them.
- Introduction of clarifications on the exception for the provision of financing for small and medium-sized enterprises, as well as certain provisions in the Annexes, relating to prohibited goods and technology;
- Adding 146 members of the Russian Federation Council to the sanctions list, as those individuals ratified the government decisions of the ‘Treaty of Friendship, Cooperation and Mutual Assistance’ between Russia and the two break-away regions in Donetsk and Luhansk;
- Adding 14 persons to the sanctions list, as they supported and benefited from the Government of the Russian Federation and/or provided substantial revenue to it; or are associated with listed persons or entities.
- Prohibition on the listing and provision of services, on Union trading venues, in relation to shares of Belarus State-owned entities;
- Prohibition on transactions with the Central Bank of Belarus;
- Restrictions on the provision of specialised financial messaging services (SWIFT) to certain Belarusian credit institutions and their Belarusian subsidiaries. These are:
- Belagroprombank
- Bank Dabrabyt
- Development Bank of the Republic of Belarus'
- Additional obligations on the Network Manager for air traffic management network functions of the single European Sky, particularly that the Manager rejects all flight plans that violate the Regulations;
- Further clarification (in respect of previous restrictive measures) that “transferable securities” includes crypto-assets.
News updates on communications from the Irish Department of Finance on sanctions on 2 and 4 March 2022 are available
here .
Europe -Other Information
In March 2022 the European Banking Authority (EBA) called on financial institutions to ensure compliance with sanctions against Russia following the invasion of Ukraine and to facilitate access to basic payment accounts for refugees. It also more recently published a statement addressed to both financial institutions and supervisors to ensure they make every effort to provide access for Ukrainian refugees to at least basic financial products and services. They also set out how AML/CFT guidelines should apply. You can read details of the statement here.
See news article of March 2022 where the EU agrees to exclude key Russian banks from SWIFT
Also, the EBA has designed an efficient framework for reporting of deposits subject to Russian and Belarusian economic sanctions. You can read more about it by clicking this link.
The European Central Bank (ECB) does not impose the financial sanctions adopted by the European Union since Russia invaded Ukraine, nor does it monitor banks’ compliance with them. However, sanctions can have implications for banking supervision and as banking supervisor, the ECB monitors the impact sanctions can have on banks. The ECB has prepared FAQs on Russia-Ukraine war and ECB Banking Supervision and you can click here to read these FAQs.
"European Banks for Ukraine" is a website which contains information on the European banking sector’s response to the war in Ukraine. You can read about key topics such as access to bank accounts, waiving payment transfers fees and exchange of Ukrainian hryvnia and find links in the information hub on this page .
Accountancy Europe have issued a useful publication ‘War in Ukraine – what European accountants need to know’ which highlights the main points that members need to consider in relation to AML, cybersecurity, and the implications for accounting, reporting and audit.
In March 2022,the European Competition Network (ECN), a network of 27 competition authorities within the European Union and the DG Competition of the European Commission issued a joint statement on the application of competition law in the context of the war in Ukraine. They noted that the different EU/EEA competition instruments have mechanisms to take into account, where appropriate and necessary, market and economic developments and that this extraordinary war situation may trigger the need for companies to address severe disruptions caused by the impact of the war and/or of sanctions in the Internal Market. The joint statement can be viewed on the Irish Competition and Consumer Protection Commission website.
On 9 March 2022 the European Intellectual Property office (EUIPO) in support of Ukraine adopted a number of measures in coordination with the EU institutions in the field of intellectual property. They have halted all cooperation actions with Rospatent, the Russian Federal Service for Intellectual Property, and the Eurasian Patent Organisation (EAPO). They have also taken measures to provide their fullest support to Ukrainian customers and to safeguard their IP rights while this situation prevents normal communication. More details of their statement and position can be found on their website.
The EU has created a specific Directive – the Temporary Protection Directive – to coordinate member states granting Ukrainian citizens a residence and work permit, known as a Temporary Protection Permit. This temporary protection will be valid for one year and can be extended for up to three additional years. The Directive may directly impact employers as it will afford the right to work in Ireland to those coming from Ukraine. You can read more details about it here.
On 30/31 May 2022,following a special meeting of the European Council ,it adopted certain conclusions concerning Ukraine .For example that the European Union will continue to provide support to Ukraine with a view to addressing humanitarian, liquidity and reconstruction needs and that it will continue to support the Ukrainian government in its urgent liquidity needs together with its G7 partners.
The European Commission has published new guidelines for member states following a decision to suspend the EU’s visa facilitation agreement with Russia, which gives member states wide discretion and greater scrutiny in processing applications. You can read more on the European Commission page here.
In September 2022 the European Commission signed two agreements with Ukraine which will make it possible for Ukraine to participate in the EU’s Customs and Fiscalis programmes. Ukraine may partake in the activities of both programmes with EU Members States and other participating countries. See here for a short Chartered Accountants Ireland news item on the signing.
Europe -press releases
Press statement dated 27 April 2022 by President von der Leyen following the announcement by Gazprom on the disruption of gas deliveries to certain EU Member States.
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