EU Ramps Up Sanctions: Key Updates on Russia and Belarus Measures

As the war in Ukraine enters its fourth year, the EU remains committed to its sanctions strategy, further tightening restrictions to curb Russia’s economic resilience and prevent circumvention. In line with this approach, and following a year of heightened enforcement actions and compliance expectations (see our recent blog post here), the EU has this week introduced its 16th sanctions package against Russia and has expanded its sanctions against Belarus, further aligning the two regimes.

The new sanctions against Russia include (i) an import ban on Russian primary aluminium, (ii) additional export restrictions, (iii) an extension of the EU services ban (to also cover construction services), (iv) transaction bans related to certain Russian ports, locks, and airports, and (v) new asset freeze listings. 

Notably, the EU introduced the following EU-Russia sanctions:

Trade restrictions

• Aluminium import ban: Gradual import ban on EU imports of primary aluminium from Russia (with a “phase-in period” permitting the import of 275,000 tons over a 12-month period).
• Additional export restrictions on industrial goods, including certain minerals and chemicals (such as nitrates of potassium), additional steel products, and fireworks.
• Extension of EU-services ban to also cover the provision of construction services (including civil engineering works) to the government of Russia and Russian legal persons.
• Transaction ban related to Russian ports, locks and airports: such as Astrakhan, Ust-Luga, Novorossiysk, Primorsk and Vnukovo International Airport.

• Flight ban: the flight ban now includes a possibility to designate third-country air carriers conducting domestic flights in Russia or supplying aviation goods to Russian airlines or for domestic flights in Russia.

• Prohibition to provide temporary storage for Russian crude oil: and petroleum products within the EU, even if price cap-compliant and destined for third countries.
• Export ban on certain software related to oil and gas products 
• Addition of new export restricted dual-use items: certain chemical riot control agents, software related to Computer Numerical Control (CNC) machine tools for weapon production, video-game controllers repurposed for drones, and chromium ores and compounds.

Additional Listings

• Expansion of ‘best-efforts clause’: Expansion of the ‘best efforts' clause concerning non-EU subsidiaries of EU companies for asset freeze sanctions (previously the clause was only focused on product trade restrictions). 
• Expanded list of asset freeze listings: Added 83 new designations (48 individuals and 35 entities), including those supporting the Russian military complex, active in sanctions circumvention (including a Turkish company), Russian crypto assets exchanges and in the maritime sector. 

• Extended of list of entities associated with the Russian military-industrial complex: 53 new entities have been added to the list of entities associated with the Russian military-industrial complex (including 34 non-Russian entities from countries such as China, India, Turkey, and Singapore). Entities on this list are subject to tighter dual-use and military goods export licensing requirements. 
• Expanded list of vessels subject to the port access ban: Added 74 vessels to the list of vessels subject to a port access ban and ban to provide certain maritime-related services.

The new sanctions against Belarus further align the EU-Belarus sanctions with the EU-Russia sanctions and, like the EU sanctions against Russia, inter alia, include an import ban on primary aluminium (however without a “phase-in” period), extended restrictions on dual-use items, and a services ban related to the provision of construction services (which unlike the EU-Russia sanctions is limited to the provision of services to the Belarussian government / persons acting on behalf of the Belarussian government). 

Beyond the direct sanctions on Russia and Belarus, the EU has also expanded its restrictions related to Crimea and Sevastopol and the non-government-controlled areas of Donetsk, Kherson, Luhansk and Zaporizhzhia oblasts. The restrictions now, inter alia, include (i) a services ban to provide professional services such as business and management consulting, engineering and IT consultancy services to legal persons in the specified territories and (ii) broader export bans (e.g. now including cars and certain electronics). 

As the EU strengthens its sanctions framework and expands enforcement efforts, businesses must proactively assess their compliance strategies to mitigate legal and operational risks. 

Our EU sanctions team continues to monitor sanctions developments and is happy to support. Please reach out if you would like to discuss any of the topics discussed in this blog.