Insights Blog

The EU Council approved the tenth package of sanctions in response to Russia’s invasion of Ukraine on Saturday 25 February 2023, following the European Commission’s 15 February 2023 proposal.

Restrictions on individuals and entities

A further 87 individuals and 34 entities were brought within the scope of the restrictions, bringing the total to 1473 and 205 respectively. 

Newly-sanctioned entities include three more banks (Alfa-Bank, Rosbank, and Tinkoff Bank), the National Wealth Fund of the Russian Federation and the Russian National Reinsurance Company.

The relevant decision and regulations are:

Council Decision (CFSP) 2023/432 of 25 February 2023 amending Decision 2014/145/CFSP

Council Implementing Regulation (EU) 2023/429 of 25 February 2023 implementing Regulation (EU) No 269/2014

Council Regulation (EU) 2023/426 of 25 February 2023 amending Regulation (EU) No 269/2014

Sector-specific sanctions

These include:

  • New export restrictions on sensitive dual-use and advanced technologies that contribute to Russia’s military capabilities and technological enhancement (including additional electronic components used in Russian weapons systems (drones, missiles, helicopters, other vehicles), together with bans on specific rare-earths and compounds, integrated circuits, and thermographic cameras with military applications).  96 new entities have been added to the list of entities who directly support Russia’s military and industrial capabilities (bringing the total to 506).
  • Additional export bans on critical technology and industrial goods, including specialised vehicles, machine parts, spare parts for trucks and jet engines, together with goods for the construction sector that can be directed to Russia’s military (e.g. antennae and cranes).
  • A prohibition on providing gas storage capacity in the EU to Russian nationals, natural persons residing in Russia or legal persons or entities established in Russia.
  • Further import bans on goods that generate significant value for Russia (bitumen and related materials such as asphalt, and synthetic rubber).
  • A ban on Russian nationals serving on governing bodies of Member States’ critical infrastructure entities.
  • The widening of the suspension of broadcasting licences in the EU to two additional Russian media outlets (RT Arabic and Sputnik Arabic).
  • A requirement that private flights between the EU and Russia, directly or via third countries, be notified in advance.
  • A prohibition on the transit of dual-use goods and firearms via Russian territory to third countries.

The EU has extended the exemption from the prohibition on entering into any transactions with certain Russian state-owned entities, if such a transaction is strictly necessary for the wind-down of a joint venture or similar legal arrangement, to 31 December 2023.  The period during which Member States’ competent authorities can authorise transactions which are necessary for the divestment and withdrawal by those Russian state-owned entities from EU companies has also been extended.

New reporting obligations have been imposed on individuals and legal entities (including financial sector entities, insurance and reinsurance undertakings, central securities depositaries and central counterparties) to provide (no later than 2 weeks after 26 February 2023) to their competent authority and to the European Commission, information on the assets and reserves of the Central Bank of Russia that are held by them.  That information must be updated every 3 months.

Other amendments have been made to allow for the provision of pilot services where necessary for maritime safety, and to deal with the release by Member States’ customs authorities of goods which are physically in the EU and which had already been presented to customs authorities when they became subject to sanctions.

The relevant decision and regulation are:

Council Decision (CFSP) 2023/434 of 25 February 2023 amending Decision 2014/512/CFSP

Council Regulation (EU) 2023/427 of 25 February 2023 amending Regulation (EU) No 833/2014

We will publish updates as developments occur. In the meantime, for more information, please get in touch with any member of our Sanctions and Export Controls Group, or your usual Arthur Cox contact.