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Almost exactly two years after the invasion of Ukraine by Russian forces, the European Union has extended its sanctions measures with the 13th sanctions package. Such sanctions package’s core is the further restriction of Russia’s access to military technologies, for example drones, as well as the listing of a further 194 companies and individuals involved in Russia’s war efforts. This increases the number of listed persons to more than 2,000.
The (newly) listed persons and entities include, inter alia:
The sanctions also include stricter trade measures. For example, 27 Russian and third-country companies have been added to the list of entities associated with Russia’s military-industrial complex (Annex IV of Regulation 833/2014).
The list of high-tech goods which may contribute to Russia’s military and technological rearmament or to the development of its defense and security sector has been expanded. These include components used in the development and manufacture of drones, such as electrical transformers, static converters and inductors, which are used, inter alia, in drones, as well as aluminum capacitors used in military applications, for example, in missiles and drones and in communication systems for aircraft and ships.
The United Kingdom is now considered a partner country for iron and steel imports. Partner countries, such as Switzerland, also apply restrictive measures to iron and steel imports and import control measures which essentially correspond to the measures of EU Regulation (EU) No. 833/2014.
The end of the sanctions spiral has not been reached
Companies must continue to monitor the current restrictive measures and adapt their processes to any changes. The large number of newly listed persons and companies results in increased effort for companies because the implementation of the newly listed persons in the electronic screening tools can take several days, during which a more stringent (manual) check is required in order to avoid any violation of the sanctions regulations.
The inclusion of the United Kingdom in the list of partner countries should provide relief for the steel sector, which is currently under heavy pressure (CBAM, German Supply Chain Due Diligence Act, anti-dumping, Russia sanctions), but this must first be implemented in the work processes.
Legal sources:
Council Regulation (EU) 2024/745 of February 23, 2024
Council Implementing Regulation (EU) 2024/753 of February 23, 2024
Sven Pohl
Director
Attorney-at-Law (Rechtsanwalt)
Mareike Höcker
Manager
Attorney-at-Law (Rechtsanwältin)
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