12th package of sanctions tightens foreign trade restrictions and introduces new measures to combat sanctions circumvention

The EU’s new restrictive measures against Russia include a ban on the import of diamonds, a tighter oil price cap and a broader scope of prohibitions on imports, exports and transit of goods. A new measure will require Russian-owned companies operating in the EU to provide notification of transfers of funds. Sanctions on individuals will be targeted at persons organising illegal elections in the territories of Ukraine, entities supporting the Russian military, and an EU citizen who has circumvented the sanctions in Finland.

On 18 December 2023, the EU decided to extend its sanctions in response to Russia’s continuing attacks on civilian targets and critical infrastructure in Ukraine as well as the illegal elections organised by Russia in the temporarily occupied areas of Ukraine.

The 12th sanctions package adds to the list of sanctioned individuals Russian officials responsible for organising illegal elections in the Ukrainian areas temporarily occupied by Russia and persons and companies supporting the Russian armed forces. In future, persons who have benefited from the forced transfer of ownership or control over Russian subsidiaries of EU companies may also be added to the list of sanctioned individuals (new listing criterion).

The additional restrictions on foreign trade aim to prevent Russia from acquiring revenue or dual-use products and other goods that benefit Russia’s military and technological capacities or the development of its defence and security sector.

The sanctions package includes a ban on imports of non-industrial diamonds from Russia as of January and a gradual ban on imports from third countries beginning in March, in accordance with the policy agreed by the G7 countries. Import bans will be imposed on liquefied petroleum gas (LPG) and butane as well as iron, copper and aluminium products. New export bans will include chemicals, lithium batteries, thermostats and motors that can be used in unmanned aerial vehicles, as well as machine tools and machine parts. Software for business management or industrial design and manufacturing will be added to the list of banned software services.

New measures to prevent circumvention of sanctions

In order to prevent sanctions circumvention, the implementation of the oil price cap mechanism introduced in December 2022 will be specified by imposing an obligation to notify of the sale or export of a tanker to any country. In the agreement concerning the sale or export of a tanker, the seller or exporter must consider the prohibitions on the use, resale or re-export of the tanker for the transport of Russian crude oil or petroleum products in certain cases. With regard to oil transport, companies are required to issue more detailed attestations.

Persons who have been found to circumvent sanctions, including an EU citizen detained in Finland, will be added to the list of sanctioned individuals.

The ban on transit through Russia of products subject to sanctions will be expanded to include engines, pumps and filters, among others. Going forward, companies must include a prohibition on the re-export of certain goods subject to sanctions to Russia in their trade agreements. 

In relation to the prohibition on providing crypto-asset wallet, account or custody services to citizens or residents of Russia, Russian citizens will be banned from owning or controlling, or holding any posts on the governing bodies of companies or other entities involved in such services in the EU.

Russian-owned companies and banks operating in the EU will be required to report on certain money transfers to third countries. The Member States must evaluate this information to prevent circumvention of sanctions.

Member States must designate an authority responsible for tracing and freezing the funds of sanctioned entities with the aim of preventing circumvention of sanctions under the Council Regulation on individual sanctions.

Derogations

The derogation possibility that allows European companies withdrawing from Russia to transfer sanctioned goods in corporate acquisitions will be extended until the end of June 2024.

In addition, the possibility to grant a derogation for the sale of companies owned or controlled by certain entities subject to sanctions will be continued.

A new derogation possibility will be created for the sale of property owned or controlled by a person or entity subject to sanctions when the property is expropriated in the public interest. 

Sanctions regime targeting individuals and entities

Sanctions regime targeting sectors

Inquiries

  • Pia Sarivaara, Team Leader, Unit for Public International Law, tel. +358 295 350 660
  • The email addresses of the Ministry for Foreign Affairs are in the format firstname.lastname@gov.fi.