The 13th package of EU-Russia sanctions

1. The 13th EU sanctions package against Russia – further amendments to EU sanctions law

On 23.02.2024, the EU member states once again agreed on a comprehensive package of sanctions in response to Russian aggression and the war waged by Russia in Ukraine. Since 24.02.2024, these regulations have entered into full force and thus both extensions of trade-related and personal sanctions, which have led to changes in the respective classification under the existing EU Regulations 833/2014 and 269/2014.

These measures were symbolically adopted on the second anniversary of the full-scale invasion and a particular focus of the measures can be seen in the limitation of military operational capability. The extended measures outside the 13th package, which EU member states agreed on following the death of Kremlin critic Alexej Navalny, can also be described as symbolic.

2. Additions to the list of designated persons and entities

The EU member states have taken the new package of measures as an opportunity to add senior employees of companies important to Russia’s military operations to the sanctions lists. These include senior personnel of important logistics service providers such as Sovfracht JSC, Marine Trans Shipping LLC, M Leasing LLC, MG-Flot LLC (formerly TransMorFlot LLC), Azia Shipping Company LLC and LLC NOVELCO. Other actors in the state apparatus of power, such as sectoral or regional government officials and military leaders, as well as judges making decisions in the interests of the state, have been identified and are now also on the sanctions list. Furthermore, some key actors responsible for the illegal deportation of Ukrainian children to Russia have been identified. A total of 106 additional natural persons and 88 legal entities have been listed. These include companies that are particularly important for Russia’s armament. These also include logistics companies such as those listed above.

In connection with the death of Alexei Navalny, the member states have agreed to include 33 individuals and two organizations on the sanctions lists who are held responsible for the ongoing and serious repression of fundamental human rights in Russia.

3. Goods-related and sectoral sanctions

The focus of the goods-related amendments to EU-Regulation 833/2014 is the restriction of military operational capability, particularly with regard to the use of drones. The trend of also targeting companies not based in Russia or Belarus is being continued as part of the 13th EU sanctions package. The sanctions now extend to companies in the United Arab Emirates, Uzbekistan, Singapore, Sri Lanka, Hong Kong, China, Serbia, Kazakhstan, Thailand, Turkey and, of course, Iran.

The 13^th EU sanctions package not only contains tighter existing regulations. For example, the United Kingdom has been added to the list of partner countries for iron and steel imports in accordance with Annex XXXVI of EU-Regulation 833/2014. Proof of import of iron and steel products from the United Kingdom, see Art. 3g para. 1, d), is therefore no longer required.

The 13th EU sanctions package thus reflects increasingly perceptible dividing lines in geopolitical systems. It should be in the interest of the EU Member States to deliberately limit these dividing lines on a sectoral and company-specific basis in order to avoid creating far-reaching trade barriers with important economic partners by way of wider escalating economic sanctions.

4. Comment

The EU sanctions against Russia are robust, unprecedented regulations with an enormous level of detail. The measures encourage the Russian government to take measures to circumvent the sanctions, so that constant monitoring and further development is required on the part of the EU member states. The aim of the sanctions is to target the Russian state and allied states such as Belarus, as well as the individual economic sectors and individuals covered by the sanctions. This objective should not be lost sight of when enforcing sanction regulations. The sanctions regulations are associated with far-reaching and complex compliance tasks. In view of the depth of detail of the regulations, legal advice should be sought in the event that a need for advice is identified; overview-type publications cannot replace advice in individual cases. This also applies to this article.

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