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Dear clients,

As of 15 March 2022 a new regulation regulating further anti-Russian sanctions in connection with the ongoing Ukraine crisis has been published in the Official Journal of the European Union.

The Council Implementing Regulation (EU) 2022/427 of 15 March 2022 implementing Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, which is available here, extended the sanctions list by an additional 15 additional persons and 9 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.

Furthermore, the Council Regulation (EU) 2022/428 of 15 March 2022 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:

• Prohibition on investing in Russian companies active in the energy sector, including prohibiting the granting of loans and credits to such persons or the creation of joint ventures with such persons, or the provision of investment services related to the activities of such persons;

• Prohibition on the export of equipment, technology and services for the energy industry;

• Prohibition the importation of iron and steel products listed in Annex XVII (p. 22 et seq.) if they originate in Russia or have been exported from Russia, and on the purchase, transport or provision, directly or indirectly, of technical assistance, brokering services, financing or financial assistance related to such products, in particular various plates, strips, sheet metal products, bars, profiles, reinforcing steel, wire, railway material, tubes, rods, wires, all as specified in Annex XVII to the Regulation;

• Prohibition on the sale, supply, transfer or export of luxury goods listed in Annex XVIII to any natural or legal person, entity or body in Russia or for use in Russia, which prohibition shall apply to luxury goods listed in Annex XVIII (page 31 et seq.) if their value exceeds EUR 300 per item, unless otherwise specified in the Annex;

• Prohibition on entering into any transactions with certain state-owned enterprises listed in Annex XIX (page 45);

• Prohibition the provision of any rating services to any Russian person or entity, as well as the provision of access to any subscription services related to rating activities.

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