EU expands sanctions against Russia and tackles sanctions circumvention

The 14th EU sanctions package deploys significant new measures to prevent the circumvention and evasion of sanctions imposed on Russia. Among a slew of new measures the package addresses issues related to aviation and the shadow fleet, expands export bans, imposes additional restrictions on Russian liquefied natural gas (LNG) revenues, and increases the obligations of businesses to tackle sanctions circumvention. The list of individuals subject to asset freezes and travel bans will also be significantly extended.

Announced in the context of the Foreign Affairs Council meeting, the EU’s 14th sanctions package significantly increases restrictive measures targeting the Russian war of aggression. The EU is expanding its import and export bans and restrictions related to sensitive technologies and products required for offensive warfare, and imposing limits on Russian LNG revenues.

The EU is also listing a number of representatives of the Russian armed forces, political operators, information influencers, opinion-formers, and business influencers who support or benefit from the Russian government. Officials of the Russian occupation administration and individuals who participated in the forced relocation of Ukrainian children in Russia and Belarus will also be added to the list.

The EU is tackling the shadow fleet that seeks to circumvent the oil price cap mechanism. The 14th package includes a new list of shadow vessels and bans the provision of services to these vessels within the territory of the EU. The EU will also limit the ability of Russian entities to conduct air freight and road haulage operations in EU territory. Russian entities will no longer be eligible to seek protection of patents and other intellectual property rights within the EU.

The new sanctions package also stresses the duties and responsibilities of EU businesses in complying with EU sanctions law. EU businesses must ensure that sanctions are not circumvented through undertakings that they own or control in third countries. They must also apply adequate due diligence measures and know-your-customer (KYC) procedures. The ability of businesses to claim and pay compensation for terminating business operations related to Russia will be expanded.

A growing number of Western and like-minded countries implement sanctions in a uniform way. Uniform measures are being applied by the USA, Japan, South Korea, Australia, Canada, New Zealand, Norway, Switzerland, Liechtenstein and Iceland.

The list of individuals subject to personal sanctions and the export ban list will be significantly expanded.

Ministry for Foreign Affairs recommends basic sanctions course for businesses

Together with partners in the public and private sector the Ministry for Foreign Affairs has published a comprehensive free training course on sanctions. The course includes modules on enhancing sanctions expertise in businesses. The Ministry recommends that the entire staff – including managements - of businesses complete the course. The course may be found on the eOppiva virtual training platform in Finnish(Link to another website.) and in English(Link to another website.).

Businesses should also study the Ministry's expert guidance on detecting and preventing sanctions circumvention.

The individual and corporate sanctions regime

The sectoral sanctions regime

Inquiries

Pia Sarivaara, sanctions team leader, international law unit, tel. +358 29 535 0660

All personal e-mail addresses at the Finnish Ministry for Foreign Affairs are in the format firstname.lastname@gov.fi.