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21 July 2022

Russia Sanctions: 7th sanctions package

The 7th sanctions package of the EU was published in the Official Journal. Both Regulation (EU) 269/2014 (individual financial sanctions) and Regulation (EU) 833/2014 (trade restrictions, capital market restrictions, etc.) have been modified.

Regulation (EU) 269/2014 – most relevant points:

  • New listings of sanctioned individuals (natural and legal persons) include persons who are involved in the recruitment of Syrian mercenaries, Russian military officials, members of the governing party and members of puppet governments installed in occupied parts of Ukraine. Most importantly, Sberbank and the FORSS Group are now listed in Annex I of Regulation 269/2014..
  • Amendment of Art 9 (Circumvention): The newly introduced paras 2 et seq. of Article 9 are noteworthy in multiple regards: Para 2 states that persons listed in the Annex (although, based strictly on the wording, not entities controlled by them) must notify Member State authorities of funds or economic resources which they own, hold or control (provided the assets are situated in the EU) until a certain deadline (Obligation to Notify) and must cooperate with authorities in the verification of this information (Obligation to Cooperate). Anyone who violates these obligations to inform and cooperate becomes criminally liable: Para 3 provides that failure to comply with the provisions of paragraph 2 will be "deemed" to constitute participation in circumvention.


Regulation (EU) 833/2014 (see here) – most relevant points:

  • Prohibition on the import of gold into the European Union: It will be prohibited to import gold into the European Union (Art 3o) if it is exported from Russia after 22 July, regardless of whether it is imported directly from Russia or a third country, and regardless of whether Russian gold has merely been incorporated into the final product. This also entails a prohibition on financing or brokering services for such exports. Exceptions apply for diplomatic purposes, cultural goods and personal use.
  • Prohibition to engage in transactions with entities listed in Annex XIX (Article 5aa): Several exemptions have been amended or added (see para 3), inter alia, an exemption for "transactions which are strictly necessary to ensure access to judicial, administrative or arbitral proceedings in a Member State", and "transactions, including sales, which are strictly necessary for the wind-down, by 31 December 2022, of a joint venture or similar legal arrangement concluded before 16 March 2022".
  • Prohibition of providing access for Russian ships and vessels:  The prohibition on Russian ships and vessels accessing European ports will be extended to any locks in Unions waters from 29 July (Art 3ea para 1).
  • Several Annexes have been amended:
    • Annex IV (Potential Military End Users)
    • Annex VII (= goods and technologies referred to in Article 2a = prohibited export goods which might contribute to military or technological enhancement)
    • Annex IX (Model for export forms)
    • Annex X (= goods and technologies referred to in Article 3b = prohibited export goods suited for oil refining or liquefication of natural gas)

Annex XXIII (= goods and technologies referred to in Article 3k = prohibited export goods which could contribute to enhancement of industrial capabilities)

author: Christoph Haid



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