EU sanctions against Russia: further tightening with oil price cap, new trade restrictions and service bans

  • 11/02/2022
  • Reading time 2 Minutes

The EU’s eight sanctions package against Russia was published in the EU Official Journal L 259 I on October 6, 2022. The tightened regulations have already been in force since October 7, 2022, and, for the first time, also affect Iran.

The new sanctions include in particular the following restrictions: 

  • Introduction of an oil price cap.
  • Expansion of personal sanctions list, in particular persons who played a decisive role during the fake referendums. Among other things, entry into the EU is banned and assets are frozen.
  • New import restrictions for Russian semi-finished and finished steel products, machinery and equipment, plastics, vehicles, textiles, footwear, leather, ceramics, selected chemical products and non-golden jewelry. 
  • Expansion of export bans to impede Russia’s access to military, industrial and technological goods. For example, coal, selected electronic components, goods for the aviation sector, selected chemicals and other goods covered by the Anti-Torture Regulation as well as small arms were included in the sanctions regime. 
  • New service bans, inter alia in the sectors of IT consulting, legal consulting, architecture and engineering. 

With Council Implementing Regulation (EU) 2022/1985 of October 20, 2022, Iranian citizens were, for the first time, included in the personal sanctions against Russia in Regulation 269/2014. This was made in response to Iran’s military support by drones. 

Companies continuing to do business with Russia should check and, if applicable, adjust their business transactions in light of the new sanctions. Please note that the prohibitions apply not only directly but also indirectly, i.e., the bans must not be circumvented in relation to other persons or countries either. 

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Authors of this article

Sebastian Billig


Attorney-at-Law (Rechtsanwalt)

Sven Pohl


Attorney-at-Law (Rechtsanwalt)

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