EU Russia and Belarus sanctions

Update: New Russia and Belarus Sanctions (as of 6 March 2023)

As a reaction to the decision by the Russian Federation to proceed with the recognition of the non-government controlled areas of the Donetsk and Luhansk oblasts of Ukraine as independent entities, and the subsequent decision to send Russian troops into several areas of the Ukraine, the EU has adopted economic sanctions against Russia.

The EU has thus far adopted ten packages of sanctions. After an initial package on 23 February 2022, further restrictive measures were adopted on 25 February 2022, 28 February 2022, 15 March 2022, 8 April 2022, 3 June 2022, 21 July 2022, 6 October 2022, 16 December 2022 and most recently on 25 February 2023. More sanctions can be expected to follow as the conflict in Ukraine develops.

The EU had already imposed certain sanctions against Russia in 2014. In light of the Russian annexation of Crimea and Sevastopol, the EU imposed sanctions on Russia and Russian individuals, included travel bans and asset freezes, trade restrictions with Crimea and Sevastopol, restricted access to EU capital markets for certain Russian banks and businesses, an arms embargo on Russia, an export ban on dual-use goods for military use/end-users, and export restrictions on certain sensitive technologies for oil production and exploration (see Fieldfisher press release).

Several sanctions were also extended to Belarus. A first package of additional sanctions was imposed on 2 March 2022, shortly followed by a second package on 9 March 2022, and a third package on 3 June 2022. These additional measures build upon existing sanctions against Belarus, which were last expanded in the aftermath of the presidential elections in 2020.

As these widened sanctions have significant effects on European stakeholders' business interests in Russia, Belarus and the contested areas of Ukraine, this brief provides an overview of the new measures and explains how they fit within the context of the existing sanctions.

The currently applicable sanctions regime consist essentially of four legal frameworks:

1. Denied party listings: Regulation 269/2014 imposes restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine
2. Substantial sanctions against Russia: Regulation 833/2014 imposes restrictive measures in view of Russia's actions destabilising the situation in Ukraine
3. Restrictions on trade with separatist Ukrainian regions: Regulation 2022/263 imposes restrictive measures for Donetsk, Kherson, Luhansk and Zaporizhzhia and Regulation 692/2014 for Crimea and Sevastopol
4. Substantial sanctions against Belarus: Regulation 765/2006 imposes restrictive measures in view of the involvement of Belarus in the Russian aggression against Ukraine

Regulation 269/2014 – Restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine

Asset freezes and travel bans

Regulation 269/2014 imposes financial sanctions on specific individuals and entities. In light of the recent military actions by Russia in Ukraine, the EU gradually added several hundreds of individuals and entities to Annex I of Regulation 269/2014. Currently, measures apply to 1473 individuals and 205 entities.

In the first package of the most recent sanctions, the EU added the 336 members of the Russian Parliament (the State Duma) who voted in favor of the recognition of the independence of Donetsk and Luhansk to the sanctions list, as well as 22 further individuals, three banks (Rossiya Bank, Promsvyanzbank and VEB) and one other entity (the Internet Research Agency).

The second package added further key individuals, including Russian President Vladimir Putin, Foreign Minister Sergey Lavrov, the members of the Security Council who supported the recognition of Donetsk and Luhansk, and the members of the Duma who supported the ratification of the Treaty of Friendship, Cooperation and Mutual Assistance between Russia and Donetsk and Luhansk. The scope of the list was also expanded to individuals outside Russia with the inclusion of individuals who facilitated the Russian military intervention from Belarus.

Moreover, the criteria for listing have been expanded and now include "leading business persons" in economic sectors providing substantive revenue to the Russian government. This will allow targeting the entire Russian government and their family members, oligarchs and any person active in the leading sectors of the Russian economy.

Following this trend, the EU adopted a third package of 26 additions to the sanctions list. It includes oligarchs and businesspeople in the oil, banking and finance sectors as well as government members, high-level military, propagandists and one entity.

In another addition, the EU added 160 individuals to the list on 9 March 2022. The listed individuals include Russian oligarchs and businesspeople, and their family members. Moreover, also the members of the Russian Federal Council who ratified the Treaty of Friendship, Cooperation and Mutual Assistance between Russia and Donetsk and Luhansk were listed. On 10 March 2022, the information for 37 individuals and six entities in Annex I was amended in light of a review by the Council.

The fourth package of measures added yet again 15 oligarchs, businesspeople from economic sectors providing a substantial source of revenue to the regime, lobbyists and propagandists as well as nine entities active in the aviation, military and dual use, shipbuilding and machine building sectors.

Besides the addition of 217 individuals and 18 entities, including four previously sanctioned banks, the fifth package of sanctions also added a new ground for the release of funds for diplomatic missions, consular posts or international organisations and special grounds for the listed state-owned Russian banks.

The sixth package of sanctions reacted to the developments in the conflict, by adding high-ranked military officers who played a role in the war crimes in Bucha and the siege of Mariupol. Further listings include political, propaganda and business people as well as further entities in the military sector.

The seventh package adds another 54 individuals and 10 entities, including the mayor of Moscow, further military leaders, politicians and propagandists, Sberbank, nationalist motorcycle club "the Nightwolves" and its members, and several companies involved in stealing Ukrainian grain.
 
Ensuring a more effective application of the sanctions, the EU added the facilitation of circumvention of sanctions as an additional listing criterion. Pro-Russian former president of Ukraine Viktor Yanukovich and his son, as well as individuals involved in the referenda held in several regions of Ukraine, propagandists, entities in the defence sector and the central elections committee were added to the list in the eighth package.

The ninth package added another 141 individuals and 49 entities to the list of Annex I. Moreover, in an attempt to combat food security challenges, Member States can now authorize the release of funds of certain banks or individuals playing a significant role in international trade of agricultural and food products, including wheat and fertilisers.
 
With the tenth package, the EU added Russian officials, military leaders, kidnappers of Ukrainian children and persons involved in disinformation warfare, as well as Iranian individuals supporting Russia's military, and members of the Wagner mercenary group. Amongst the listed entities are Russia's National Wealth Fund, the Russian National Reinsurance Company, Russian companies in strategic sectors such as maritime, defence, construction, infrastructure, machine building, batteries, weapons, missiles and air- and spacecraft, 3 Russian banks (Alfa-Bank, Rosbank, Tinkoff Bank), and UAE-based shipping management company SUN Ship Management. The amendments also introduce a number of company-specific derogation grounds.
 
Listed individuals and entities are subject to asset freezes and a prohibition of making available funds or resources applicable to all persons in the EU. All individuals are also subject to an EU travel ban, with the exception of for instance Russian President Vladimir Putin and Foreign Minister Sergey Lavrov.

Shortly before the adoption of the two most recent packages of sanctions, five individuals were added to the list of individuals and entities on 21 February 2022. These additions were not linked to the current security situation (press release).

Regulation 833/2014 – Restrictive measures in view of Russia's actions destabilising the situation in Ukraine

Trade and investment restrictions

The economic sanctions against Russia include a wide range of trade and investment restrictions on various economic sectors including dual-use items, defence and security, energy, aviation, maritime, steel, luxury, coal, oil and petroleum goods:

• Dual-use goods and advance technology (Art. 2 and Art. 2b-2d): The sanctions include reinforced restrictions on dual-use goods and technologies, whether originating in the EU or not, to any person or entity in Russia. The EU imposes a prohibition on the sale, supply, transfer or export of dual-use goods as defined in Annex I to the Dual-Use Regulation, as well as the provision of assistance, brokering services or other services and financing or financial assistance in relation to dual-use goods and the transit of dual-use goods via Russian territory. Exceptions apply for the case where such goods are used for non-military use, subject to a registration in the customs declaration as well as a declaration to the competent authorities of the first use. The EU Member States may also grant authorisations for the sale, supply, transfer or export of dual-use goods, subject to the conditions of Art. 2b-2d of the Regulation.
• Defence and security sector (Art. 2a and Art. 2b-2d): Restrictions are applied on goods which might contribute to Russia's military and technological enhancement and the development of the defence and security sectors, whether originating in the EU or not. This includes for instance semiconductors, cutting-edge technologies, drone engines and other chemical, biological and electronic goods (Annex VII). The restrictions are similar to trade restrictions applied on dual-use goods. Exceptions for non-military use apply and EU Member States may also grant authorisations subject to the conditions of Art. 2b-2d of the Regulation.
• Firearms (Art. 2aa): It is prohibited to sell firearms, their parts and components, and ammunition as defined by Annex I to Regulation 258/2012 on the implementation of the UN Firearms Protocol. The prohibition extends to providing technical, brokering or finance assistance and transiting firearms via Russian territory.
• Public financing of any trade or investment (Art. 2e): The EU imposed a prohibition of the provision of public financing or financial assistance for trade with, or investment in, Russia. Exceptions apply for commitments prior to 26 February 2022, financing to SMEs of up to 10 million EUR per project and financing for trade in food and trade for agricultural, medical and humanitarian purposes. The EU also added an explicit prohibition to invest, participate or otherwise contribute to projects co-financed by the Russian Direct Investment Fund.
• Energy sector (Art. 3, 3a and 3b): Sector-specific sanctions apply on goods for use in the energy sector. Currently, three restrictive measures are in place. First, the EU instated a general prohibition to trade energy-related goods (Annex II). Exceptions allow inter alia energy transportation to ensure energy security in the EU and prevent human, health or environmental disasters. Second, a general prohibition applies to participate in investments in the Russian energy, mining and quarrying sector. Limited exceptions apply for ensuring critical energy security and the transport of certain energy products back to the EU. Third, the EU imposed a prohibition of the sale, supply, transfer or export of goods and technology for oil refining or natural gas liquidification (Annex X), as well as the provision of technical assistance, brokering services or other services and financing or financial assistance on energy-related goods. Exceptions apply to prevent adverse effects on human health or nature.
• Aviation and space sector (Art. 3c): Sector-specific sanctions apply to goods and technologies suited for use in the aviation and space industry, whether originating in the EU or not (Annex XI). Restrictions include the prohibition of the export, sale and supply or transfer of aircrafts, aircraft parts or aircraft equipment, including repair, maintenance and financial services, insurance and reinsurance in relation to such goods, technical assistance, brokering services and other services, financing or financial assistance. Importantly, the overhaul, repair, inspection, replacement, modification and defect rectification are also prohibited (with the exception of pre-flight inspections). The measures were also extended to jet fuels and fuel additives, which may be used by the Russian army (Annex XX) and aircraft engines and their parts (Annex XI). Several grounds for derogations apply, including to avoid satellite disasters and also for medical, pharmaceutical and humanitarian purposes.
• Maritime navigation goods technology (Art. 3f): The EU prohibited also the sale, supply, transfer and export, as well the provision of related technical, brokering, financial or other services of maritime navigation goods and technology to any person in Russia or for placing on board of Russian-flagged vessels. The list of goods affected includes navigation equipment and radio-communication technology (Annex XVI).
• Iron and steel products (Art. 3g): The EU instated an import ban on iron and steel products originating in Russia or exported from Russia (Annex XVII). The prohibition also applies products using Russian iron and steel inputs which are processed in third countries. The prohibition is subject to several exceptions (such as for pre-existing contracts), transitional tariff rate quotas to secure supply for the EU market, and a possibility for Member States to grant ad hoc authorizations for certain purposes.
• Luxury goods (Art. 3h): An EU export ban to Russia applies to luxury goods with a value of more than EUR 300 per item. The export ban aims to affect the Russian elite's lifestyle. To that extent, the list of luxury goods includes cars, jewellery, electronics, watches, art and other food and leisure goods (Annex XVIII). An exception for cultural goods on loan in the context of formal cultural cooperation with Russia applies.
• Goods generating significant revenue in Russia (Art. 3i): Import prohibitions were instated on various goods that generate significant revenue in Russia, such as wood, cement, fertilizers, seafood, cigarettes, cosmetics and liquor (Annex XXI). Exceptions apply for diplomatic purposes and pre-existing contracts, wind-down periods temporarily allow imports of certain products up to pre-determined quotas, and Member States can grant ad hoc authorisations in certain cases.
• Coal and fossil fuel products (Art. 3j): An import ban applies to all forms of Russian coal (Annex XXII). The prohibition extends to providing technical assistance, brokering, financing and other services related to coal imports.
• High-technology goods (Art. 3k): There is a further export ban on technological and industrial goods for which Russia is dependent on EU inputs, including quantum computing, advanced semiconductors, sensitive machinery, transportation, chemicals, generators, toy drones, IT hardware, cameras, etc. (Annex XXIII). This prohibition is aimed at preventing the enhancement of Russian industrial capacities. Authorisations can be granted for medical, pharmaceutical, humanitarian purposes, long-term lease agreements of Member States, retention of civil nuclear capabilities in the Union, or where the goods or services are necessary for personal household use. A specific derogation applies to titanium goods for the aeronautic industry, for which no alternative supply is available.
• Oil and petroleum products (Art. 3m-3n): Restrictions on oil and petroleum products comprise an import prohibition and a prohibition to transport oil products. First, imports into the EU of certain crude oil or refined petroleum products from Russia (Annex XXV) shall be phased out and ultimately prohibited. Several exemptions and derogations apply. Landlocked Member states may temporarily import seaborne crude oil from Russia if the supply by pipeline is interrupted. Moreover, country-specific derogation grounds exist for the Bulgarian and Croatian competent authorities. Oil products imported under such country-specific derogation cannot be resold to buyers in another Member State. Furthermore, crude oil products under CN 2709 00 delivered by pipeline is allowed until the Council decides that the prohibitions apply, but petroleum products made from these crude oil imports cannot be transported to other Member States or third countries (except to Ukraine under certain circumstances). Finally, the prohibitions do not apply where oil purchases serve essential needs of the purchaser or of humanitarian projects in Russia. Second, the EU prohibits transportation services of oil or petroleum products from Russia. This prohibition do not apply if the purchase price of the oil and petroleum products remains under a certain price cap. The EU and the G7+ Price Cap Coalition partners agreed on a price cap on crude oil (60 USD per barrel) and petroleum products (USD 100 per barrel for premium-to-crude products and 45 USD per barrel for discount-to-crude). The price caps are intended to reduce Russia's earnings from oil and to stabilise global energy prices.
• Gold (Art. 3o): Imports of gold originating from Russia are prohibited. The prohibition extends not only gold itself, but also gold coins and jewellery (Annex XXVI). The prohibition does not apply to gold and jewellery for personal use of natural persons travelling to the EU.

A general ground for authorisation for national competent authorities was added to allow the sale or transfer of goods or technologies where such sale is strictly necessary for the divestment from Russia or the wind-down of business activities in Russia. This derogation applies to the export prohibitions of Art. 2, 2a, 3, 3b, 3c, 3f, 3 h and 3k and the import prohibitions of Art. 3g and 3i.

Financial sanctions

The EU measures target transactions with major banks and companies in several economic sectors in Russia as well as all transactions with the Russian Central Bank and Russian state-owned enterprises (SOEs):

• Access to capital markets and loans/credit (Art. 5): The EU imposed prohibitions on dealing with transferable securities and other money-market instruments. It is prohibited to purchase, sell, provide investment services for, assist in the insurance of, or otherwise deal with transferable securities and money-market instruments from several companies in the Russian economy. These include major state-owned and private credit institutions such as Sberbank, VTB Bank, Gazprombank, VEB and Rosselkhozbank, and Alfa Bank, Bank Otkritie, Bank Rossiya and Promsvyazbank (Annex III and Annex XII), companies in the military and defence sectors (Annex V), companies exporting oil products (Annex VI) and other entities (Annex XIII). Moreover, it is prohibited to grant any new loans or credits to these entities, save in certain exceptional cases where objectives have been documented or with relation to contracts concluded before 26 February 2022. Finally, it is prohibited to list, provide services for, and to admit to trading on trading venues in the EU, the transferable securities of any Russian entity with more than 50% public ownership.
• Transactions with the Russian Central Bank (Art. 5a): The EU prohibited purchasing, selling, providing investment services, insuring or otherwise dealing with certain transferable securities and money-market instruments issued by the Russian Federation, its government, Central Bank or any person acting on behalf of the Central Bank such as the Russian National Wealth Fund. Moreover, it was prohibited to be part of any arrangement to make new loans or credit to any of these entities. The EU later prohibited all transactions with the Russian Central Bank. The scope of the prohibition spans all transactions related to the management of the reserves as well as the assets of the Central Bank and covers transactions with any legal person, entity or body acting on behalf of the Central Bank. Extensive reporting obligations apply to (central) banks, financial institutions, insurance companies and central securities depositories. Exceptionally, transactions may be authorised if strictly necessary for the financial stability of the EU or a Member State.
• Dealing with SOEs (Art. 5aa): First, EU persons are prohibited to do any transactions with a number of Russian SOEs across different sectors. The targeted companies are 13 SOEs which are publically controlled, with more than 50% public ownership, where the Russian Government or Central Bank participates in the profit, or where it has significant economic relationships. Importantly, the listed SOEs include Roseft and Gazprom (Annex XIX). Limited exceptions, for instance for existing contracts, certain raw material imports, energy projects, oil and petroleum products, medical goods, and food products including fertilisers are foreseen. Transactions for the winding-down of joint ventures with Russian persons or entities can also be authorised. Second, it is also prohibited for EU persons to hold any posts in the governing bodies of these SOEs, or any company owned by the Russian State (Annex XIX). Competent authorities may authorize the holding of a post to ensure critical energy supply or when the person is involved in transiting third country oil through Russia.

Restrictions on financial and other services to Russian nationals

The EU sanctions against Russia also include several prohibitions on the provision of financial services to Russian nationals:

• Deposits and euro-denominated securities (Art. 5b-5g): The EU prohibits the acceptance of any deposits of a value of more than 100,000 EUR from Russian nationals, residents or legal persons as well as Russian-owned entities outside Russia. It is also prohibited to provide crypto-asset wallet, account or custody services to Russians. Exceptions apply for nationals of an EU Member State or persons having a temporary or permanent residence permit in a Member State, EEA country or Switzerland. EU central securities depositories are prohibited from providing any services for transferable securities to any Russian national or entity. The measures are intended to prevent the Russian elite to hide their money in the EU.
• Exclusion from SWIFT system (Art. 5h): A prohibition is in place to provide specialised financial messaging services to exchange financial data to ten Russian banks (Bank Otkritie, Novikombank, Promsvyazbank, Bank Rossiya, Sovcombank, VEB, VTB Bank, Sberbank, Credit Bank of Moscow and JSC Rosselkhozbank) and Russian subsidiaries owned for more than 50% by these banks (Annex XIV). This prohibition followed an investigation of the consequences of the measures by the ECB (press release) and political support by the Commission, France, Germany, Italy, the UK, Canada and the US (joint statement).
• Banknotes in EU-denominated currencies (Art. 5i): The EU prohibits to sell, supply, transfer or export banknotes denominated in any official currency of a Member State to Russia, save for personal use and diplomatic missions, consular posts or international organisations in Russia.
• Prohibition to provide credit ratings (Art. 5j): The EU also prohibits the provision of credit rating services and bans access to any subscription services in relation to credit rating activities for any person, resident or entity in Russia.
• Public contracts (Art. 5k): The EU restricted the participation of Russian nationals, entities and bodies in EU public procurement contracts. This means that it is prohibited to award or continue the execution of any public or concession contract with more than 10% Russian involvement.
• Excluding Russia from European money (Art. 5l): EU, Euratom or Member State programmes are not allowed to provide financial or non-financial support to Russian publicly owned or controlled entities. Exceptions apply for humanitarian, (phyto)sanitary, mobility, climate change and diplomatic purposes.
• Prohibition to advise on trusts (Art. 5m): EU persons are prohibited from advising Russian nationals on trusts. The prohibition spans services from providing registration or management, to acting as trustee, nominee, director, shareholder, secretary or any other similar position. The measures are intended to prevent Russians from storing their wealth in the EU. Several exceptions apply, notably for humanitarian purposes, civil society initiatives and social/cultural/sports activities.
• Provision of business and other services (Art. 5n): EU persons are prohibited to provide Russian persons a broad range of services, including business services (such as accounting, auditing, bookkeeping, tax consulting, business and management consulting, or public relations services), architectural, engineering, IT consultancy or legal advisory services, or market research and public opinion polling services, technical testing and analysis services and advertising services. This prohibition applies to services to the Russian Government or any Russian person, entity or body.

Restrictions on transportation

• Closure of the EU airspace (Art. 3d-3e): The EU adopted a prohibition for any aircraft operated by Russian air carriers, or for any Russian registered aircraft, or for any aircraft otherwise controlled by any Russian natural or legal person, to take off from or overfly the territory of the EU. The EU Network Manager for air traffic management shall support the implementation of this prohibition. Aircraft operators are obliged to notify non-scheduled flights to their competent authorities at least 48 hours in advance.
• Closure of the EU ports (Art. 3ea): The EU also prohibits access to EU ports any vessel registered under the Russian flag, vessels certified by the Russian Maritime Register of Shipping, and previously Russian vessels that changed their flag after February 2022. The prohibition does not apply when a vessel is seeking refuge, in case of emergencies, or when ships supply certain goods to the EU (see Annex XXIV and Annex XXII), amongst others.
• Transport (Art. 3l): Any Russian road transport undertaking is prohibited from operating in the EU. Exemptions cover agricultural and food products, humanitarian aid, energy goods as well as cultural goods on loan.

Other measures

• Suspension of broadcasting by Russian state-owned new stations in the EU (Art. 2f): In a move to halt disinformation and propaganda, the EU suspended the broadcasting activities in the EU of the Russian state-owned outlets Russia Today, Sputnik, Rossiya RTR/RTR Planeta, Rossiya 24, TV Centre International, TV/NTV Mir, Rossiya 1, REN TV, Pervyi Kanal, RT Arabic and Sputnik Arabic (Annex XV). This entails a broad prohibition on any means of broadcasting in the EU via cable, satellite, IP-TV, internet service providers, internet video-sharing platforms or applications. Moreover, EU persons are prohibited to advertise any products or services by these outlets in type of content. RT France challenged this measure unsuccessfully before the General Court (T-125/22).
• Prohibition for Russians to hold posts (Art. 5o):  Russian nationals are banned from holding posts in governing bodies of critical infrastructures companies in the EU, such as electricity grids or gas providers.  This prohibition is the counterpart of similar prohibitions for EU nationals to hold posts in Russian SOEs (cfr. Art. 5aa).
• Prohibition to provide LNG storage (Art. 5p):  A prohibition applies to provide gas storage capacity in the EU to Russian natural or legal persons. This measure is adopted in response to Russia's gas supply policy. The provision is subject to a grandfathering clause and an exception to ensure critical energy supply in the EU.
• Russia's MFN status at the WTO: The EU and other like-minded partners such as Albania, Australia, Iceland, Republic of Korea, Moldova, Montenegro, New Zealand, North Macedonia and Norway announced they will stop granting Russia MFN treatment within the WTO framework (press release). This decision followed a joint statement by the G7 (here) and action by other countries such as Canada (here). Removing MFN treatment clears the way to apply higher tariffs on Russian imports than to other WTO partners.

Regulation 2022/263 – Restrictive measures in response to the recognition, occupation or annexation by the Russian Federation of certain non-government controlled areas of Ukraine

Goods from Donetsk, Kherson, Luhansk and Zaporizhzhia are subject to a total trade ban and investment prohibitions (Regulation 2022/263). These restrictions largely mirror the existing restrictions with respect to Crimea and Sevastopol.

• Import and export ban (Art. 2): The measures impose a total import ban (subject to certain exceptions) on goods originating in Donetsk and Luhansk. In particular, the measures include a prohibition to import goods from Donetsk and Luhansk into the EU, or the provision of financing or insurance services for such imports.
• Investment prohibition (Art. 3 and 7): The measures prohibit acquiring real estate, acquiring ownership of companies, granting loans or credits, creating joint ventures or providing investment services. It leaves room, however, for certain derogations from these prohibitions subject to the strict conditions of the Regulation. 
• Export restrictions (Art. 4-6 and 7): The provision of export goods and technology, as well as certain tourism and other services are also prohibited under the Regulation. It leaves room, however, for certain derogations from these prohibitions subject to the strict conditions of the Regulation.

Regulation 765/2006 – Restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine

The EU also imposes restrictive measures on Belarus (Regulation 765/2006) and added several new measures:

• Designated individuals and entities (Art. 2 ff): The EU has subjected several Belarusian persons and entities to asset freezes and travel bans, and imposed on all EU persons and companies a prohibition to make funds or economic resources available to listed Belarusian persons (Annex I). These restrictions currently apply to 195 individuals and 35 entities. Moreover, several Belarusian individuals and entities were also added to the list of denied parties in Annex I of Regulation 269/2014 (Russia sanctions).
• Trade and investment restrictions (Art. 1a-1f and 1o-1s): The sanctions include an export prohibition on equipment used for internal repression (Annex III), military goods (Common Military List), other equipment, technology and software (Annex IV), dual-use goods and technology, goods for Belarus' military and technological enhancement, tobacco products (Annex VI), certain machinery (Annex XIV). Furthermore, import restrictions apply to a broad range of goods including mineral products (Annex VII), potassium chloride products (Annex VIII), wood (Annex X), cement (Annex XI), iron and steel (Annex XII), rubber (Annex XIII). Several exceptions apply to these export and import prohibitions, which are subject to prior authorisation of Member State authorities.
• Financial sanctions (Art. 1ja-1l and 1t-zb): The EU also adopted several financial sanctions applicable to Belarus. The sanctions are inspired by the sanctions applicable to Russia and include, inter alia, prohibitions on transactions with the Central Bank of Belarus, the provision of services on state-owned trading venues, new loans or credit to Belarusian persons, the provision of insurance services, financing or providing financial assistance for investments in Belarus, amongst others. Deposits exceeding EUR 100,000 from Belarusian nationals cannot be accepted, unless a derogation is obtained, and banknotes of any EU currency cannot be supplied. EU central securities depositories cannot provide services to Belarusian nationals and transferable securities denominated in any Member State currency are prohibited. Four Belarusian Banks are excluded from using the SWIFT financial transaction processing system.
• Other restrictions (Art. 1zc, 8b-8ca): Belarusian road transport companies are not allowed to operate in the EU and Belarusian air carriers cannot enter the EU airspace.

The EU sanctions have the clear objective to discourage trade with Russia and Belarus. Business operators have to be very prudent in both business planning and transactions, and should be aware of several pitfalls arising from the restrictive measures. Even where the EU sanctions will allow certain business activities, restrictions in force can impede the receipt of payments.

For further information on the EU Russia sanctions, please contact Jochen Beck.