Companies & corporate law

New sanctions package agreed

Key elements

The new sanctions package includes the following elements:

  • New export restrictions. The new export restrictions are designed to limit Russia’s access to military, industrial and technological products; they include a ban on the export of coal, including coking coal, electronic components that are found in Russian weapons technical products used in the aviation sector, and certain chemicals.
  • New import restrictions. According to Brussels, the import restrictions are expected to be worth nearly €7 billion. Among other things, it is envisaged, a ban on the import of Russian finished and semi-finished steel products (subject to a transition period for certain semi-finished products), machinery and equipment, plastics, vehicles, textiles, footwear, leather, ceramics, certain chemical products and jewelry other than gold (which has been sanctioned in previous sanctions packages).
  • Oil price ceiling. Agreed as part of the G-7 deal, the price ceiling on oil exports is designed to reduce Russia’s revenues while maintaining stability in energy markets and preventing inflation. The ceiling is to take effect after December 5, 2022 for crude oil and after February 5, 2023 for refined oil products.
  • Restrictions on the provision of legal, financial, business and IT consulting services. The package broadens the scope of services that can no longer be provided to the Russian government or to legal entities based in Russia (not applicable to companies owned or controlled by EU companies, among others): from now on they also include IT consulting, legal consulting, architectural and engineering services.
  • Sanctions for circumventers. Member states have agreed that the criterion for listing sanctioned individuals and entities is to facilitate violations of the prohibition on circumventing sanctions.
  • Prohibition of EU citizens from holding certain positions. EU citizens will not be allowed to hold positions in the governing bodies of certain Russian state-owned or controlled legal entities, entities or bodies.
Author team leader DKP Legal Magdalena Napierała
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