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26 June 2023

Russia Sanctions: 11th sanctions package

The 11th sanctions package with amendments to Regulation 269/2014 (here and here) and Regulation 833/2014 (here) was published in the Official Journal (here) on Friday.

The changes can be summarised as follows:

For mergers and acquisitions:

  1. Big Russian players such as Lukoil, Yandex and Ozon are still not sanctioned
  2. It is possible to apply for a temporary licence to advise regarding removing/firewalling the Russian mother company (including if it is listed) from EU business (Article 5n 833/2014)
  3. There are special authorisations pertaining to VTB (which might prove helpful with regard to Fortenova, for example) and NSD (Art 5a 269/2014) as well as to the sale of DRs (Art 5aa 269/2014)
  4. There are special authorisations pertaining to the acquisition of entities/assets related to Mordashov (Art 5c 269/2014)
  5. There are additional authorisations pertaining to exits from Russian subsidiaries/joint ventures, incl. the provision of transitional services (Art 12b 833/2014)
  6. There are special authorisations pertaining to exits from Russian companies that operate as pipeline infrastructure, incl. the provision of goods and technology (Art 12b (1a) 833/2014)

Additional listings

  • Over 100 additional individuals and entities subject to asset freezes (see the newly listed entities and individuals)

Trade measures

  • New anti-circumvention tool: possible to restrict export to certain third countries
  • Addition of 87 new entities to the list of those directly supporting Russia's military and industrial complex in its war of aggression against Ukraine (see Annex IV New Entities Military End Users)
  • Restriction on the exports of a further 15 technological items found on the battlefield in Ukraine or equipment needed to produce such items (see Annex VII New Items Dual Use/Military)
  • Extension of the transit prohibition for certain sensitive goods (e.g. advanced technology, aviation-related materials) exported from the EU to third countries via Russia.
  • Tightening restrictions on imports of iron and steel goods by requiring importers of sanctioned iron and steel goods that have been processed in a third country to prove that the inputs used do not come from Russia
  • Prohibition on the sale, licensing or transfer of intellectual property rights and trade secrets used in connection with restricted goods to prevent sanctioned goods from simply being manufactured outside the EU. Please note: there is EU guidance that the prohibition on licensing IPRs also applies in the context of import restrictions (and falls under "Other services")
  • Extension of the ban on the export of luxury cars to all new and second-hand cars above a certain engine size (> 1,900 cm³) and all electric and hybrid vehicles. There is also a complete ban on certain types of machinery components (see Annex XXIII Restricted Export Goods)
  • Simplifying the structure of the industrial goods annex by listing products subject to restrictions in one single section and with broader product definitions in an effort to better identify goods subject to export bans and reduce circumvention of sanctions by misclassification (see the respective "new version" of Annexes XXI and XXIII)

Transport measures

  • A full ban on trucks with Russian trailers and semi-trailers from transporting goods to the EU. This will clamp down on the circumvention of the prohibition on Russian freight road operators carrying goods to the EU
  • Prohibition on vessels that engage in ship-to-ship transfers suspected to be in breach of the Russian oil import ban or G7 coalition price cap accessing EU ports
  • Prohibition on vessels accessing EU ports if they do not notify the competent authority at least 48 hours in advance about a ship-to-ship transfer occurring within the exclusive economic zone of a Member State or within 12 nautical miles of the baseline of that Member State's coast
  • Prohibition on vessels which manipulate or turn off their navigation tracking system when transporting Russian oil subject to the oil import ban or G7 price cap accessing EU ports

Energy measures

  • End of the possibility for Germany and Poland to import Russian oil by pipeline
  • Insertions of derogations to the existing export bans to enable the maintenance of the CPC (Caspian Pipeline Consortium) pipeline, which transports Kazakh oil to the EU through Russia
  • Extension of the exception to the oil price cap for Sakhalin oil for Japan (until 31 March 2024)

Additional clarifications

  • Revision of the listing criterion for individuals/entities engaged in the circumvention of EU sanctions, including those significantly frustrating EU sanctions
  • Addition of a new listing criterion to allow persons and entities operating in the Russian IT sector to be granted a licence by the Federal Security Service (FSB) or the Ministry of Industry and Trade of the Russian Federation
  • Insertion of certain clarifications in the provision on information sharing between competent authorities and maintaining confidentiality in communications between lawyers and their clients in the context of reporting obligations
  • Insertion of an exemption for the provision of pilot services in specific circumstances


  • Extension of the media ban to five additional channels (RT Balkan, Oriental Review, Tsargrad, New Eastern, Outlook Katehon)

author: Christoph Haid



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