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The EU’s Tenth Sanctions Package

Author: Nicola Sharp  27 February 2023
2 min read

Rahman Ravelli details the key points in the latest package of sanctions announced by the European Union.

The European Union has agreed a 10th package of sanctions against Russia and those that support its illegal invasion of Ukraine.

The package includes a number of significant measures that build upon the sanctions already imposed by the EU.

These include:

  • Export bans on critical technology and industrial goods, such as electronics, specialised vehicles, machine parts and spare parts for trucks and jet engines. The bans also cover goods that are used in the construction sector, including cranes and antennae.
  • Further restrictions on the export of dual-use goods and advanced technology goods. This includes 47 new electronic components that can be used in Russian weapons systems such as drones, missiles and helicopters.
  • Export restrictions on specific rare earth materials and thermal cameras.
  • Import bans on Russian high-revenue goods, such as bitumen and related materials like asphalt, synthetic rubber and carbon blacks.

The package also includes the addition of seven Iranian entities to the EU’s Russia dual-use sanctions. This is a response to the Iran Revolutionary Guards’ alleged provision of Shahed drones to be used to attack civilian infrastructure in Ukraine.

People and Entities

A total of almost 100 people and entities are sanctioned under the new package.

These include:

  • Those involved in the kidnapping, deportation to Russia and forced adoption of Ukrainian children.
  • Those enabling the looting of Ukrainian resources.
  • Organisations involved in the Russian military and defence sector, including those responsible for the development of drones that are targeting civilians and civilian infrastructure.
  • Key decision makers, senior government officials and parliamentarians.
  • Proxy authorities and judges in non-government-controlled Ukrainian regions of Luhansk, Donetsk, Kherson and Zaporizhzhia.
  • Media organisations, people and entities responsible for disinformation.

The package also contains measures to prevent circumvention. These include the creation of an “overview” of all frozen assets of the Russian central bank held in the EU alongside Member States. Three Russian banks have been added to the list of entities subject to the asset freeze and the prohibition to make funds and economic resources available. Other measures include a ban on Russian nationals serving on governing bodies of Member States' critical infrastructure companies, a prohibition on Russian nationals and entities booking gas storage capacity in the Union (excluding liquefied natural gas), measures to facilitate the divestment from Russia by EU operators, and a requirement of advance notification of any private flights between the EU and Russia, either directly or via third countries.

In addition, the EU sanctions envoy David O'Sullivan has been reaching out to third countries, to ensure strict implementation of sanctions and prevent circumvention. On 23 February, the first Sanctions Coordinators Forum took place in Brussels, gathering Member States and other countries to strengthen enforcement efforts.

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Nicola Sharp


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Nicola is known for her fraud, civil recovery, arbitration and business crime expertise, her experience of leading the largest financial disputes and multinational investigations and her skills in devising preventative measures and conducting internal investigations for corporates.

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