In the first half of 2023, two additional packages of sanctions were adopted by the EU in the context of the Ukrainian crisis.

10th package of sanctions On 25 February 2023, the EU adopted a tenth package of restrictive measures against Russia through a set of regulations amending or implementing existing regulations and completing sanctions already adopted between February and July 2022 (please read here) and in December 2022 (please read here).

It added not only individuals and entities to the list of designated persons, but also measures against individuals in Iran supporting Russia by elaborating certain equipment for Russia's military. In addition, new export and import bans and restrictions were introduced. In addition, three additional Russian banks were designated and two media outlets were added to the media ban. Other measures involved a ban on Russian nationals from serving on governing bodies of Member States' critical infrastructure companies, a prohibition for Russian nationals or entities to book gas (other than LNG) storage capacity in the Union as well as certain measures to facilitate divestments from Russia. In the field of enforcement and anti-circumvention measures, new reporting obligations were imposed on Russian Central Bank Assets.

11th package of sanctions On 23 June 2023, an 11th package of restrictive measures was published, which entered into force on 24 June 2023. The measures have added individuals and entities to the list of persons subject to asset freezes and have expanded the list of goods and technology subject to specific restrictions. They now also include bans on vessels suspected or found in breach of EU sanctions from accessing EU ports and locks.

Additional anti-circumvention measures include, in particular, the possibility to restrict the sale, supply, transfer or export of certain goods and technology to certain third countries. They also provide for the possibility to prohibit the provision of technical assistance, brokering services or other services as well as of financing or financial assistance for such goods to persons in these countries or for use in these countries. The prohibition on the sale, license or transfer of intellectual property rights or trade secrets also applies to these countries and goods. At present, however, the EU has identified neither goods or technology subject to these restrictions, nor targeted specific third countries. It is expected that these tools will only be used as a last resort if cooperation or other measures fail to prevent circumvention.

There are also new reporting obligations: EU economic operators have to supply immediately any information which would facilitate the implementation of EU sanctions to the competent authority of their Member State within two weeks of acquiring this information – an obligation which previously only existed for asset freeze measures.

Further guidanceFor further information on international and EU sanctions, including a list of applicable EU regulations and affiliated texts and their interpretation, reference can be made to the dedicated webpages of the Luxembourg Ministry of Finance (which includes useful best practice guides and forms), the CSSF and the European Commission. The latter includes a consolidated FAQ, last updated on 30 June 2023, and the useful EU sanctions map.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.