11th package of EU sanctions against Russia focuses on preventing sanctions circumvention

The European Union introduces significant new instruments in its eleventh package of restrictive measures against Russia to prevent circumvention and evasion of sanctions, particularly through third countries. These instruments include several facilities for targeting sanctions against parties that circumvent sanctions and assist in such circumvention. Export bans, bans on transit through Russia and individual sanctions lists are expanded.

The EU expands the sanctions that it imposed in response to the Russian war of aggression against Ukraine. This is now the eleventh EU sanctions package arising from the invasion. The newly approved sanctions package introduces significant new measures to prevent sanctions circumvention.

The ban on transit of export-controlled goods through Russia is extended. The EU prohibits the transit through Russia of products and technologies that may be used to enhance Russian military and technological capabilities, and to develop the defence and security sector. The transit ban will now include aviation and space industry products and technologies, aviation fuels and their additives.

A new mechanism is introduced to prevent circumvention of sanctions. This mechanism may be applied to companies in third countries that have systematically failed to prevent the transit to Russia of goods subject to sanctions. It would be applied as a last resort if the desired outcome could not be achieved through diplomatic negotiations with these countries.

Export licences permitted by the regulation will be withheld from entities operating in third countries that have participated in circumventing sanctions or assisting in such activity.

The criteria for targeting sanctions against sanctions busters is also expanded. Individuals who promote infringement of the ban on evading sanctions set out in Council decisions and regulations, or who otherwise systematically act in a manner contrary to the purpose of sanctions may be subject in future to individual sanctions.

Sanctions regulations expand the list of individuals and entities that are subject to sanctions. Representatives of the Russian armed forces or persons who support them, political operators, information influencers of Russian society, opinion formers and business influencers who support the Russian government or benefit from it will be added to the list. Some of the individuals listed are responsible for arranging the enforced relocation and illegal adoption of Ukrainian children. The entities listed are Russian state agencies, state-supporting organisations, undertakings that have supported the Russian armed forces, banks and media enterprises.

Products and technology that are used for maintaining Russia’s military apparatus and industrial capacity are added to the scope of export bans. These include electronic components, semiconductor materials, materials for making electronic circuits and printed circuit boards, source materials for energetic materials and chemical weapons, optical components, navigation instruments, and metals used in the defence sector and shipping.

Import bans on products that generate revenue for Russia to finance its invasion are expanded. These include coal products, lignite, peat products, non-hydrocarbon gases, and tar and pitch distilled from coal.

Derogations may also be granted for providing services required for establishing, certifying or evaluating the safeguard known as a firewall. Such firewalls seek to remove the right of a sanctioned individual to exercise control over the assets of an entity (such as an undertaking) that is not on the sanctions list, but is owned or controlled by the said individual within the territory of the EU.

A previously imposed operating ban is expanded by prohibiting the use of trailers registered in Russia within EU territory, even when towed by trucks that are registered in the EU and in third countries.

Restrictions on access to Union ports and locks will continue. The ban is extended to include vessels:

  • that import, purchase or transport products that are subject to sanctions.
  • that are suspected of being or have been found to be in violation of the ban on importing Russian crude oil or oil products, and of the oil price cap imposed by the G7 group (vessel to vessel transfer).
  • that illegally jam, turn off or otherwise disable their navigation systems when transporting Russian crude oil and petroleum products, except for safety and environmental reasons or in order to save lives.

The sale, licensing and transfer of trade secrets and intangible assets to Russia is prohibited.

Previous regulations concerning the importation of iron and steel products that are processed in third countries and contain Russian iron and steel products is clarified.

The provision of legal advice to Russian operators leaving the EU market is permitted until 31 March 2024.

Derogation possibility for the withdrawal from Russia of European company subsidiaries established in Russia is extended until the end of 2023. The derogation concerns the transfer of products subject to sanctions that are held by the subsidiary in the context of a business acquisition.

The individual and corporate sanctions regime

The sectoral sanctions regime


Pia Sarivaara, Counsellor (Sanctions Team), Unit for Public International Law, Tel. +358 29 535 0660

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