Companies & corporate law

The 7th package of sanctions has been in effect since July. Personal sanctions renewed until March 15, 2023

The seventh package of EU sanctions, dated July 21, 2022, has been dubbed a “holiday package,” and not just because of the period in which it took effect – it bypasses the most controversial demands for new sanctions in the areas of energy and fuel imports; instead, it focuses only on sealing the existing ones. At the same time, on September 14, it was announced that personal sanctions would be extended until March 15, 2023.

Key elements

Despite critics’ reservations, July’s sanctions package is not completely without bite. Brussels has banned the purchase, import and transfer of gold and jewelry from Russia, including those exported to third countries after July 22, 2022. The ban also covers fine jewelry and handcrafted jewelry. It is worth recalling that Russia is the world’s second largest exporter of this metal ore.

The provision of credit rating services to or for any Russian nationals or individuals residing in Russia or any legal entities, entities or bodies based in Russia has also been banned. The ban on accepting deposits, which was already in effect, was expanded, and as well as the list of dual-use items and technologies.

Procedure clarification

From a practical standpoint, the most important element of the new sanctions package is the clarification of existing regulations. It has been emphasized that the existing sanctions do not apply to trade in agricultural products between Russia and EU countries (unless sanctioned entities are involved) and third countries, which had previously caused various controversies. There is also a clarification of the procedure for exceptions to export bans by competent national authorities granting authorizations on the basis of the exceptions provided for in Regulation 833/2014.

Personal sanctions extended until March 2023. When will new sanctions be imposed?

In a communication dated September 14, 2022, the Council (EU) announced the extension of individual sanctions for another 6 months. The sanctions include a ban on the entry of individuals on the sanctions list, as well as the freezing of assets of sanctioned individuals and entities and a ban on providing them with financial and other economic resources. The sanctions will continue to subject 1206 individuals and 108 entities.

As of yet, there is no confirmed information on when Brussels plans to introduce a new sanctions package. However, press reports indicate that talks are continuing all the time in this regard, the subject of which is, among other things, the controversial demand to introduce a visa freeze for citizens of the Russian Federation.

We would like to remind you that specialists from our law firm have been providing specialized advice to entrepreneurs and entities operating on markets in Poland and the European Union since the introduction of sanctions on a large scale.

Author team leader DKP Legal Magdalena Napierała
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