The EU’s tenth sanctions package and other restrictive measures imposed by foreign states

A year after the start of the special military operation in Ukraine, the USA, the EU, the UK and other foreign states have introduced new restrictive measures against Russia (sanctions). In February 2023, practically all countries that have introduced sanctions against Russia significantly extended the list of personal sanctions as well as imposing further restrictions on the export and import of particular goods.

Presented below is a round-up of the key new restrictions imposed by the EU, the USA and the UK.

The EU’s tenth sanctions package

Personal sanctions

The EU has primarily imposed blocking sanctions against the following categories of persons:

• Companies of the military-industrial complex;
• Major Russian banks (Alfa Bank JSC, Rosbank PJSC, Tinkoff Bank JSC).

The EU has so far imposed blocking sanctions on 1,499 individuals and 208 companies[1]. The sanctions include asset freezes and bans on EU individuals and companies from providing funds to sanctioned persons.

In addition, sanctions for the circumvention of the EU sanctions regime have been imposed on Iranian citizens for the alleged development and supply of unmanned aerial vehicles (UAVs) to the Russian Federation, as well as on seven Iranian entities involved in manufacturing UAVs[2].

Trade restrictions

Additions have been made to the list of industrial goods and critically important technologies which are prohibited from being supplied to Russia[3]. In particular, restrictions have been placed on Russia’s access to certain electronic components which can be used in UAVs, missiles and helicopters. Restrictions have also been imposed on the supply to Russia of rare-earth elements and construction machinery (fork-lift trucks, cranes, bulldozers, etc.)[4].

Another import change is the ban on the transit via the territory of Russia of dual-use goods[5]. Prior to the introduction of the tenth sanctions package the EU only prohibited the supply of dual-use goods to Russia.

The EU has imposed a ban on imports of certain goods from Russia, such as paraffin, petroleum coke, bitumen, asphalt, bituminous mixtures, carbon, and synthetic rubber (some prohibited goods may be imported subject to certain conditions)[6].

New bans for Russian citizens

Russian citizens are prohibited from holding management positions in European entities that are operators of critical infrastructures or from using gas storage capacity (except for some liquefied natural gas facilities)^[7]. Critical infrastructures include those operated by entities in the energy and transport sectors, etc. Competent bodies of EU states must independently identify critical infrastructures by 17 July 2026[8].

New obligations for European banks

The EU has introduced new obligations for European financial organisations with respect to the reporting of frozen assets. The new legislation establishes a minimum list of information to be supplied on frozen assets and the time limits for notifying competent authorities of EU states[9].

New US sanctions

Personal sanctions

The Specially Designated Nationals and Blocked Persons list (SDN) was extended on 24 February 2023. Blocking sanctions have been imposed against certain companies, including enterprises of the military-industrial complex, the metallurgical sector and the mining industry[10].

Large Russian banks have also been included in the SDN, including Moscow Credit Bank PJSC, Bank Uralsib PJSC, MTS-Bank PJSC, Zenit Bank PJSC, AKB Metallinvestbank PJSC, SDM-Bank PJSC, AKB Lanta-Bank JSC, and Sankt-Peterburg Bank PJSC[11]. Unlike the EU, the USA has not imposed blocking sanctions on Tinkoff Bank JSC.

In addition, secondary sanctions have been imposed on companies in Switzerland, Bulgaria, Cyprus and Malta which the USA believes have helped Russia to circumvent sanctions (the Maltese company Stratton Investment Group Ltd, the UAE-based companies Taerio Limited and Tamyna FZE, et al.)[12].

Trade restrictions

The US Department of Commerce has significantly extended the list of luxury articles for which an additional permit (licence) is required for shipment to Russia. Luxury articles now include smartphones priced higher than USD 300 and domestic appliances (such as refrigerators, freezers, extractor hoods, coffee machines, electric kettles, washing machines, etc.)[13]. The EU has already imposed similar restrictions on supplies of expensive domestic appliances to Russia.

In addition, the US Department of Commerce has imposed personal trade restrictions against 89 entities from Russia and other countries (for example, KAMAZ PJSC, Megafon PJSC, Skolkovo Technology Park, et al.)[14]. Companies included in the Commerce Department’s list are subject to more stringent export controls (including on re-export and transit). In particular, a licence is generally required to supply goods to the entities concerned.

US import restrictions include increased duties on imports to the USA from Russia of certain metals, minerals and chemical products[15]. In addition, the US President ordered a 200% duty to be imposed on aluminium products made in Russia from Russian raw materials[16].

New UK sanctions[17]

Personal sanctions

The UK has extended its sanctions list to include Russian top executives, board members of major defence companies and executives of Iranian companies which manufacture UAVs[18]. The UK has also imposed sanctions against certain large Russian banks: Uralsib Bank PJSC, Sankt-Peterburg Bank PJSC, Zenit Bank PJSC and MTS-Bank PJSC[19].

Trade restrictions

The UK has banned the export to Russia of goods which can be used for military purposes. These include aircraft parts, radio equipment, electronic components for the manufacture of UAVs, etc.[20]

In addition to export restrictions, the UK has prohibited the import of 140 goods including products made from Russian iron and steel[21].

Sanctions imposed by other states

Besides the USA, the EU and the UK, other countries such as Canada[22], Japan[23], Australia[24] and Switzerland[25] have also imposed personal and trade restrictions aimed at weakening Russia’s military potential.

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The B1 team is ready to provide assistance in connection with the new sanctions and to help minimise potential risks.