Compliance26.02.2024 Newsletter

EU adopts 13th sanctions package against Russia

The EU has adopted the thirteenth package of sanctions against Russia. In time for the second anniversary of the Russian war of aggression against Ukraine, the representatives of the 27 EU member states have imposed additional sanctions against Russia. Around 200 individuals, companies and organisations are affected.

Sanctioning of around 200 additional natural persons and legal entities

The new sanctions package adds 194 individuals, companies and organizations to the EU sanctions list. This significantly expands the list of individuals and entities whose assets are frozen in the EU. It now includes more than 2,000 companies and individuals. In addition to financial sanctions, the European Commission is also imposing travel bans to the European Union.

The EU Commission is pursuing various objectives with the new financial sanctions:

Combating sanctions evasion: The EU is taking strong measures to combat sanctions evasion. As a result, the new EU sanctions list now includes a Russian logistics company and its director who are involved in parallel imports of listed goods into Russia, as well as another Russian actor who is also involved in a sanctions-evading procurement activity.

Sanctioning supporters of Russia's war of aggression: Ten Russian companies and individuals involved in the supply of defense equipment from North Korea to Russia are also added to the EU sanctions list. They include the North Korean Defense Minister and several Belarusian companies and individuals who support Russia's armed forces..

The EU is stepping up its action against Russia’s temporary occupation and illegal annexation of territories in Ukraine: Six judges and ten officials working in the occupied territories of Ukraine have been added to the EU sanctions list.

Sanctioning violations of children's rights: The EU sanctions list now also includes 15 individuals and two organisations involved in the forced transfer, deportation and military indoctrination of Ukrainian children, including in Belarus.

New export restrictions

The 13th sanctions package provides for further export restrictions:

The list in the new Annex IV of Regulation (EU) No. 833/2014 is supplemented by 27 Russian companies and companies from third countries, which contribute to the military and technological strengthening of Russia. According to Art. 2(7), 2a(7) and 2b(1) of Regulation (EU) No. 833/2014, the sanctioned companies may not receive from the EU any dual-use goods and technologies that could contribute to the arming of the Russian defense and security sector. The new restrictions include four companies based in China (RG Solutions Limited, Guangzhou Ausay Technology Co. Limited, Shenzhen Biguang Trading Co. Ltd. and Yilufa Electronics Ltd. ), one in Kazakhstan (TOO Elem Group), one in India (Si2 Microsystems Pvt. Ltd.), one in Serbia (Conex Doo Beograd-Stari Grad), one in Thailand (Thai IT Hardware Co. Ltd.), one in Sri Lanka (Euro Asia Cargo (Private) Ltd.) and one in Turkey (Yild-iz Çip Teknoloji Elektronik Elektrik Bilgisayar Malzemeleri Ticaret Sanayi Limited Sirketi). The measures are intended in particular to prevent transactions aimed at circumventing the EU sanctions.

The new package also includes further export restrictions on goods that can be used to manufacture drones. Drone technologies are a central element of Russian warfare against Ukraine. In order to weaken Russia's offensive capabilities, the new Annex VII of Regulation (EU) No. 833/2014 now lists goods used for the development and manufacture of such drones. The export restrictions under Art. 2a(1) and 2b(1) of Regulation (EU) No. 833/2014 include the following goods:

  • Electrical transformers,
  • Static converters and inductors, which can be found in drones, among other things,
  • Aluminium capacitors that can be used for military purposes, for example in missiles and drones as well as in communication systems for aircraft and ships.

The sanctions package extends the list of goods in Annex XXIII of Regulation 833/2014 that could especially contribute to the development of Russian industrial capacities to all goods of tariff heading 8504, i.e. all "electrical transformers, power converters (e.g. rectifiers) and reactors", instead of only goods of CN codes 850432, 850433 and 850434.

Strengthening existing import bans

The new sanctions package also addsthe United Kingdom to the list of partner countries for iron and steel imports. The partner countries, which also include Switzerland and Norway, apply a set of restrictive measures on iron and steel imports and related control measures that are substantially equivalent to the measures in Regulation (EU) No. 833/2014.

Entry into force of the sanctions package

The amendments to the thirteenth sanctions package against Russia entered into force on 23 February 2024.

What should companies do now?

As with previous sanctions packages, companies will need to assess whether existing and new business relationships are now subject to sanctions. At the same time, it is important to monitor whether the products or technologies manufactured and distributed are affected by the new prohibitions.

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Mareike Heesing<br/>LL.M. (Köln/Paris I)

Mareike Heesing
LL.M. (Köln/Paris I)

Junior PartnerAttorney

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