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Dear clients,

As of October 6, 2022 a new regulation regulating further anti-Russian sanctions in connection with the ongoing Ukraine crisis, forming the eighth sanctions package, has been published in the Official Journal of the European Union.

The Council Regulation (EU) 2022/1906 of 6 October 2022 amending 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 30 additional persons and 7 entities and institutions 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.

These include, in particular, members of the State Council Department, persons involved in organising the illegal referendum in Zaporizhzhya, Donetsk and Kherson oblasts and persons appointed to leading positions in these oblasts by the Russian government, military officials and some prominent Russian propaganda figures. They also include JSC Goznak, certain companies involved in arms production, aircraft construction and entities involved in the illegal elections in the occupied areas of Ukraine.

Furthermore, the Council Regulation (EU) 2022/1904 of 6 October 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 the sale, supply, transfer or export of civilian firearms and their main parts and ammunition, military vehicles and equipment, paramilitary equipment and spare parts;

• Prohibition on holding positions on the governing bodies of legal persons, entities or bodies established in Russia whose ownership or share of profits or significant economic relationship with them is held by the Russian Government or the Central Bank or entities in Annex XIX;

• Extending the ban on imports of goods such as steel, wood, paper, precious metals and stones, cigarettes, engineering and chemical products, plastics and certain finished chemical products such as cosmetics and others from Russia;

• Prohibition on the provision of cryptoasset wallet, cryptoasset account or cryptoasset custody services to Russian persons and residents, regardless of the total value of such cryptoassets;

• Prohibition on the provision of services such as accounting, auditing, architectural, engineering, legal and IT consulting services to the Russian government and to legal persons, entities or bodies established in Russia;

• Clarification of existing restrictive measures on imports of crude oil and petroleum products.

This regulation also establishes the basis to put in place a price cap related to the maritime transport of Russian oil for third countries and further restrictions on the maritime transport of crude oil and petroleum products to third countries.

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