Further EU sanctions package against Russia

  • 03/17/2022
  • Reading time 3 Minutes

Goods affected include oil and gas exploration, rating services, steel products, luxury items and smartphones.

On March 15, 2022, the EU adopted another package of sanctions against Russia and published it in the EU Official Journal No. 87I on the same day, affecting, among other things, goods for oil and gas exploration, rating services, steel products, and luxury items for everyday use, such as smartphones.  

On the one hand, the sanctions package provides for the inclusion of another 15 persons and 9 organizatinos in Annex I of Regulation (EU) No. 269/2014 with DURCHFÜHRUNGSVERORDNUNG (EU) 2022/427  i.e., the list of individuals or legal entities, organizations and bodies subject to restrictive measures has been supplemented again. 

With REGULATION (EU) 2022/428, Regulation (EU) No. 833/2014  was expanded to include additional prohibitions and sanctions:

  • Art. 3: A general prohibition on the sale, supply, transfer and export of goods listed in Annex II for oil and gas exploration, including related technical assistance, brokering services or other services, and the provision of financing and financial assistance, was established.

  • Art. 3a: Prohibition of participation in the energy sector, including the granting of loans or other financial assistance and the provision of investment services in this sector.

  • Art. 3g: Prohibition of import and transport of the iron and steel products listed in Annex XVII (goods of chapters 72 and 73) originating in or exported from Russia.

  • Art. 3h Comprehensive export ban on all Annex XVIII goods classified as luxury goods. In addition to classic luxury goods such as caviar, breeding horses, high-value watches and jewelry, various everyday products are also affected, including sports equipment (skis or golf), household appliances such as refrigerators and smartphones, vehicles worth 50,000 euros or more, etc. However, unless otherwise specified in Annex XVIII, goods whose value does not exceed EUR 300 per item are excluded.

  • Art. 5aa: Prohibition of all direct and indirect transactions with state-owned enterprises listed in Annex XIX.

  • Art. 5j: Providing rating services to Russian persons or entities or granting them access to corresponding subscription services shall be prohibited.

  • Extension of Annex IV of Regulation (EU) No. 833/2014.

We strongly recommend that companies compare their own business transactions with the extended sanctions lists. This includes, on the one hand, a review of the stock list to determine whether any goods are subject the new goods-related restrictions. On the other hand, the extended list of persons should be taken into account as part of business partner screening.

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Authors of this article

Sebastian Billig


Attorney-at-Law (Rechtsanwalt)

Sven Pohl


Attorney-at-Law (Rechtsanwalt)

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