10th sanctions package adopted

Updated sanctions list

As a result of the new sanctions package, the list of “designated” individuals and entities, i.e. those whose funds and assets are frozen within the European Union, has expanded by another 121 entries. Inclusion on the sanctions list means that assets belonging to these persons and entities are no longer available to them within the Union, and all persons and entities operating within the Union must refrain from providing funds and economic resources to designated persons.

Sectoral bans

The new package introduces additional export restrictions on sensitive dual-use and advanced technologies that contribute to Russia’s military and technological capabilities. Export bans are now also imposed on goods that can be easily diverted for use in support of Russian military operations, including:

– heavy trucks previously not banned (and their spare parts), trailers and special vehicles such as snowmobiles;

– goods that can be used by Russian troops: including electric generators, binoculars, radars, compasses, etc;

– construction goods, such as structures for tower-type buildings, forklifts, cranes, etc;

– electronics, machine parts, pumps, metalworking machinery, etc;

– bitumen and related materials, such as asphalt; and

– Synthetic rubber and carbon black.

A ban on Russian nationals from serving on governing bodies of Member States’ critical infrastructure companies was also introduced.

Strengthening measures to prevent circumvention of sanctions

The agreed sanctions package introduces a restriction on the transit of dual-use goods and weapons to third countries through Russian territory. It was also announced that new reporting obligations will be imposed on frozen funds and assets, including on pre-sanctions transactions, as well as improved cooperation between member states and the European Commission in introducing and sealing the European sanctions regime.

We would like to remind you that specialists from our law firm have been providing specialized counseling in this area since the beginning of the introduction of sanctions, addressed to entrepreneurs and entities operating on the markets in Poland and the European Union.