Insights Blog

The eleventh package of EU sanctions against Russia was finalised last week and published in the Official Journal on Friday 23 June.

Key Targets / Restrictions

Key aspects of this latest round of sanctions include:

  • Asset Freeze: Adding 71 individuals and 33 entities to the list of persons who are subject to asset freezes and who cannot have funds and economic resources made available to them.  New entities added to the list include Russian IT companies that supply key technology and software to Russian intelligence, and two banks (MRB Bank and CMR Bank).
  • Export Restrictions:
    • 87 new entities are now be subject to stricter export restrictions for dual-use and advanced technology items.
    • The restriction on exports of certain industrial goods that reinforce Russia’s industrial base has been tightened and simplified to make it easier for customs officials to check compliance.
  • Transit ban: The transit ban (which previously covered dual-use goods and firearms) has been extended to advanced technology products, aviation goods, jet fuel and fuel additives.
  • New anti-circumvention tool: The EU may (as a last resort) restrict the sale, supply, transfer or export of specified sanctioned goods and technology to certain third countries (and the provision of associated services) where the EU feels that other measures and outreach to those third countries has not been enough to prevent circumvention of the EU’s sanctions against Russia. The focus of this tool is on goods and technologies which facilitate military aggression by Russia, such as dual-use goods and technology or goods that could enhance Russia’s military, technological and industrial capacity.
  • Ships: A ban on accessing to EU ports and locks by ships:
    • engaged in ship-to-ship transfers where competent authorities have reasonable cause to suspect that the relevant ship is breaching the Russian oil import ban or G7 Coalition price cap; or
    • that do not notify the relevant competent authority at least 48 hours in advance about a ship-to-ship transfer occurring within specific geographical areas; or
    • which illegally interfere with, switch off or otherwise disable their shipborne automatic identification systems when transporting Russian crude oil and petroleum products.
  • Crude Oil: The temporary derogation granted to Germany and Poland for the supply of crude oil from Russia through the northern section of the Druzhba oil pipeline has ended. Oil originating in Kazakhstan or another third country will be able to continue to transit through Russia and be imported into the EU via the Druzhba oil pipeline.
  • Iron and Steel: Linked to the eighth package of sanctions (read our insights on that package here), restrictions on imports of iron and steel goods have been tightened.
  • Trucks: A full ban has been introduced on trucks with Russian trailers and semi-trailers from transporting goods to the EU.
  • Intellectual Property: Restrictions have also been imposed on EU companies transferring their industrial know-how and trade secrets directly or indirectly to any person, entity or body in Russia, or for use in Russia.
  • Media: Restrictions have been imposed on five additional Russian media outlets (RT Balkan, Oriental Review, Tsargrad, New Eastern Outlook and Katehon).
  • Transferable Securities: To bolster the prohibition on providing transferable securities to persons in Russia, that prohibition has been extended to financial instruments denominated in any currency.
  • Notable derogations:
    • Member States’ competent authorities may continue to allow the provision of legal services needed to help EU persons divest themselves from the Russian market until 31 March 2024.
    • A derogation has been added allowing the provision of services required for the establishment of a firewall removing the control by a listed person over the assets of an EU entity.
    • A derogation allowing the sale of proprietary rights in a Russian joint venture co-owned with a listed person.


Clarifications included in the latest round of sanctions relate to:

  • The processing and exchanging of information by Member States’ competent authorities.
  • The confidentiality of communications between lawyers and their clients in the context of existing and newly introduced reporting obligations.
  • The exchange of information between competent authorities, customs and financial supervisors, within the same and among different Member States, in particular in relation to circumvention patterns and attempted circumvention.

Reporting Obligations

To avoid forum shopping, Member States must now share any decision to reject an application for authorisation with both the European Commission and other Member States within 2 weeks.

Further Information

The press release and FAQ from the European Commission are here and here.

The press release from the EU Council is here: Russia’s war of aggression against Ukraine: EU adopts 11th package of economic and individual sanctions.

The relevant decisions and regulations are here:

For more information, please get in touch with any member of our Sanctions and Export Controls Group, or your usual Arthur Cox contact.