Further EU sanctions against Russia: group of sanctioned persons expanded, restrictions on maritime shipping and on exports of radiocommunications technology

Sven PohlLaw

With two further regulations this week, the EU has expanded and tightened the previous sanctions against Russia. The measures relate, on the one hand, to the expansion of the group of persons subject to restrictive measures. There are further restrictions on the export of maritime goods and radio communications technology to Russia. Furthermore, individual terms and provisions of the already adopted sanctions regulations have been further clarified. An important clarification was made regarding the restrictions on “transferable securities”: these also include crypto securities which can be traded on the capital market.

 

Implementing Regulation (EU) 2022/396 of March 9, 2022, added a total of 160 persons to Annex I of Regulation (EU) No. 269/2014 who are subject to a freezing of assets as well as direct and indirect provision prohibitions. The newly listed persons include 146 members of the Federation Council of the Russian Federation and another 14 persons who support and benefit from the Government of the Russian Federation.

Regulation (EU) 2022/394 of March 9, 2022, introduces a ban on the sale, supply, transfer and export of maritime goods and technologies listed in Annex XVI. The ban applies to direct or indirect sales and transfers to persons, entities and bodies in Russia or for use in Russia or for carriage on board a vessel flying the Russian flag. All services and assistance related to these technologies are prohibited as well.

Furthermore, Annexes VI, IX, and XIII are amended, which includes, in particular, a further specification of the prohibited goods and technologies’ provisions.
Companies that continue to do business with Russia should verify that their business partners are not directly or indirectly designated on the new sanctions lists. In addition, one should check whether the expansion and specification of the embargo's lists of goods affect the company's own products to take countermeasures in good time, if necessary, since the sale is already prohibited and thus punishable.

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