Insights Blog

The EU Council adopted the 12th package of EU sanctions against Russia on 18 December 2023.

Key measures include:

  • A direct ban on diamonds exported from Russia from 1 January 2024. An indirect import ban on Russian diamonds processed in third countries (to be phased-in between 1 March and 1 September 2024).
  • EU exporters must contractually prohibit re-exportation to Russia and re-exportation for use in Russia of particularly sensitive goods and technology, when selling, supplying, transferring or exporting to a third country, with the exception of partner countries.
  • Tighter export restrictions concerning dual use goods and technologies for 29 entities.
  • An expanded list of restricted items that could contribute to the technological enhancement of Russia’s defence and security sector.
  • Further import restrictions on goods which generate significant revenues for Russia.
  • A new import ban on certain types of liquefied petroleum gases, subject to a 12-month transition period.
  • Limited exemptions from import restrictions for certain personal use items, for cars that have diplomatic vehicle registration plates, and for cars belonging to EU citizens living in Russia.
  • The existing transit ban applicable to dual use goods and technologies exported from the EU to third countries via Russia will be extended to all battlefield goods.
  • A ban on Russian nationals owning, controlling or holding any posts on the governing bodies of those providing crypto-asset wallet, account or custody services to Russian persons and residents.
  • The existing ban on the provision of services will be extended to include the provision of software for the management of enterprises and software for industrial design and manufacture.
  • A derogation enabling, subject to specific conditions, the granting of loans or credit to entities operating in the Russian energy sector.
  • Notification requirements for the transfer of funds outside the EU by any entity established in the EU that is owned or controlled by an entity established in Russia, or by a Russian national or natural person residing in Russia.
  • All sales of EU operators’ tankers will need to be notified to national authorities, and sales to Russian persons / entities or for use in Russia will require authorisation. This to address concerns regarding ‘shadow fleets’ / deceptive practices designed to circumvent the oil price cap.  Information-sharing will also be strengthened to better identify practices such as ship-to-ship transfers and manipulations of automatic identification systems while transporting Russian crude oil and petroleum products.  After a transition period, a requirement will also be introduced that itemised price information for ancillary costs such as insurance and freight be supplied to enforcement authorities (on request) throughout the supply chain.
  • Adding Switzerland to a list of partner countries which apply restrictive measures on imports of iron and steel from Russia. Wind-down periods for the import of specific steel products have been extended.
  • Restrictive measures on a further 61 individuals and 86 entities, including one of Russia’s largest insurance companies. The names of deceased individuals will also be capable of being retained on the list if their assets could otherwise be used to finance Russia’s invasion of Ukraine.

Further information:

Council Regulation (EU) 2023/2878 amending Regulation (EU) No 833/2014

Council Regulation (EU) 2023/2873 amending Regulation (EU) No 269/2014

EU Council Press Releases: here and here

European Commission Questions and Answers

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