legal update - ukraine


Dear clients,

As of 25 February 2023, new regulations were published in the Official Journal of the European Union regulating the tenth anti-Russian sanctions package in connection with the one-year anniversary of the Russian invasion of Ukraine, which provides for a significant extension of import and export restriction measures and expands the list of persons on the EU sanctions lists.

The Council Regulation (EU) 2023/427 of 25 February 2023, amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, available here, extended the already effective anti-Russian sanctions and also imposed new sanctions, in particular:

• Extension of the list of goods and technology prohibited from being purchased, imported or transferred to the EU to include:

 petroleum jelly;

 petroleum coke, petroleum bitumen and other residues of petroleum oil or of oil obtained from bituminous minerals;

 bitumen and asphalt, natural; bituminous or oil-shale and tar sands; asphaltites and asphaltic rocks;

 bituminous mastics, cut-backs and other bituminous mixtures based on natural asphalt, on natural bitumen, on petroleum bitumen, on mineral tar or on mineral tar pitch;

 carbon (carbon blacks and other forms of carbon not elsewhere specified or included);

 synthetic rubber and factice derived from oils, in primary forms or in plates, sheets or strip; mixtures of natural rubber, balata, gutta-percha, guayule, chicle or similar types of natural rubber with synthetic rubber or factice, in primary forms or in plates, sheets or strip.

• Extension of the list of goods and technologies prohibited to be sold, supplied, transferred or exported to Russia to include various electronics, specialised vehicles, machine parts, spare parts for trucks and jet engines, as well as construction goods that may be destined for the Russian military, such as antennas or cranes, in particular:

 various engines and their components,

 pumps, burners,

 furnaces, heaters,

 construction machinery and their accessories,

 manufacturing machines and their components, robots,

 generators, transformers and other electrical apparatus and machinery,

 electronic components

 tractors and other goods vehicles, as well as parts for them,

 miscellaneous minerals and minerals,

 lime,

 coal,

 various industrial gases and chemical compounds,

 precious metals used in industry,

 dyes, paints, varnishes, sealants,

 lubricants,

 films, photographic paper,

 polymers, resins and certain products thereof

 cellulose and certain products thereof,

 sanitary ware (baths, washbasins, toilet bowls, etc.),

 doors, windows,

 rubbers and some of their products,

 wood and some wood products,

 paper, cardboard,

 various fabrics, threads,

 Asphalt products,

 building materials (bricks, blocks, roof tiles,

 some iron and other metal products.

• Prohibition on Russian nationals or natural persons residing in Russia from holding any position in the management bodies of owners or operators of critical infrastructures, European critical infrastructures and critical entities.

• Prohibition on the provision of natural gas storage capacity (except LNG) to Russian nationals and legal persons owned by them or acting on their instructions.

• New notification obligations for flight operators of non-scheduled flights between the EU and Russia.

• Suspension of EU broadcasting licenses for RT Arabic and Sputnik Arabic

Furthermore, the Council Implementing Regulation (EU) 2023/429 of 25 February 2023 implementing Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, available here, extended the sanctions list by an additional 96 entities which are subject to, in particular:

• Asset freeze.

• Travel ban to EU countries.

• Restrictions of EU citizens and companies which are forbidden from making funds available.

• Tighter export restrictions are imposed regarding dual-use goods and goods and technology which might contribute to Russia’s technological enhancement of its defence and security sector.

In case of any questions about the above, we of course remain available to you.