On February 23, 2024, the EU adopted the 13th package of sanctions against Russia with the occasion of the 2nd year mark of the full-scale invasion.1

This package focuses on further limiting Russia's access to military technologies, such as for drones, and on listing additional companies and individuals involved in Russia's war effort. With this new package the number of individual listings has reached over 2000.2 The key elements of the 13th package are the following:

Designations

This is an unprecedented package of 194 individual designations, including 106 individuals and 88 entities. With it, the EU exceeds the threshold of 2000 listings. The designations specifically target:

  1. Russia's military and defense sector (including manufacturers of missiles; drones, anti-aircraft system, military vehicles, high-tech components for weapons and other military equipment);
  2. Third country public administrations, corporations and individuals partnering with Russia for the provision of military equipment (the designations target the Defence Minister of the DPRK, as well as several Belarusian companies and individuals);
  3. Entities involved in circumvention;
  4. Individuals and entities involved in violation of children rights;
  5. Authorities from occupied territory: six judges and 10 officials in the occupied territories of Ukraine.

Those designated are subject to an asset freeze and EU citizens and companies are forbidden from making funds available to them. Natural persons are additionally subject to a travel ban, which prevents them from entering or transiting through EU territories.

Import-export controls and restrictions

The EU added 27 new entities to the list3 of those directly supporting Russia's military and industrial complex in its war of aggression against Ukraine. They are now subject to tighter export restrictions concerning dual use goods and technologies, as well as goods and technology which might contribute to the technological enhancement of Russia's defence and security sector.

Some of these entities are located in third countries (India, Sri Lanka, China, Serbia, Kazakhstan, Thailand, and Turkey) and have been involved in the circumvention of trade restrictions, others are Russian entities involved in the development, production and supply of electronic components for Russia's military and industrial complex.4

The new sanctions package also expands the list of restricted items that could contribute to the technological enhancement of Russia's defence and security sector5 by adding components for the development and production of unmanned aerial vehicles (UAV) such as electric transformers, static converters and inductors as well as aluminum capacitors.

Lastly, the EU introduced further restrictions on exports of goods which contribute in particular to the enhancement of Russian industrial capabilities, such as electrical transformers.6

Iron & steel

The EU has added the United Kingdom to a list of partner countries which apply a set of restrictive measures on imports of iron and steel from Russia.7

Curtis is closely monitoring any legislative development. Curtis is committed to provide the best advice to its clients on how to navigate the complex regulatory environment.

Footnotes

1. See: Council Implementing Regulation (EU) 2024/753 of 23 February 2024 implementing Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, OJ L, 2024/753, 23.02.2024, available at: https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=OJ:L_202400753. Also: Council Regulation (EU) 2024/745 of 23 February 2024 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia's actions destabilising the situation in Ukraine, OJ L, 2024/745, 23.02.2024, available at: https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=OJ:L_202400745

2. EU Commission press release, EU adopts 13th package of sanctions against Russia after two years of its war of aggression against Ukraine IP 24-963 (Feb. 23, 2024), available at: https://ec.europa.eu/commission/presscorner/detail/en/ip_24_963

3. Annex IV referred to in Articles 2(7), 2a(7) and 2b(1) of Council Regulation (EU) No. 833/2014.

4. EU Council of the European Union, Russia: two years after the full-scale invasion and war of aggression against Ukraine, EU adopts 13th package of individual and economic sanctions(Feb. 23, 2024), available at: https://www.consilium.europa.eu/en/press/press-releases/2024/02/23/russia-two-years-after-the-full-scale-invasion-and-war-of-aggression-against-ukraine-eu-adopts-13th-package-of-individual-and-economic-sanctions/

5. Annex VII containing the List of goods and technology referred to in Articles 2a(1) and 2b(1) of Council Regulation (EU) No. 833/2014.

6. Annex XXIII containing the List of goods and technology as referred to in Article 3k of Council Regulation (EU) No. 833/2014.

7. Annex XXXVI List of partner countries for importation of iron and steel as referred to in Articles 3g(1) of Council Regulation (EU) No. 833/2014.

Originally published 28 Feb. 2024

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.