1.07.2024

Alert: EU adopts 14th package of sanctions against Russia

On the 24th of June 2024, the European Union adopted the 14th package of sanctions against the Russian Federation. These restrictive measures are aimed to target new sectors of the Russian economy and reinforce anti-circumvention mechanisms.

This new sanction’s package includes the following texts:

I. Additional list of entities under sanctions

This 14^th package extends the list of entities under sanctions to 69 individuals and 47 entities, responsible for actions that undermine or threaten Ukraine’s territorial integrity, sovereignty, and independence.

II. Measures relating to the energy sector

To prevent EU facilities from being used to transfer Russian liquefied natural gas (LNG) to third countries, the EU prohibits the rerouting of Russian LNG on the EU territory for transshipment to third countries. Importantly, this disposition does not affect the import of Russian LNG into the EU but restricts its re-export to third countries via EU ports.

Additionally, the EU imposes restrictions on new investments, as well as on the provision of goods, technology, and services for ongoing LNG projects such as Arctic LNG 2 and Murmansk LNG.

III. Anti-circumvention mechanism

EU operators are required to undertake best efforts to ensure that legal persons, entities and bodies established outside the EU that they own or control do not participate in activities that aim to circumvent sanctions.

EU entities engaged in the sale of military equipment to third countries are required to implement control mechanisms designed to identify and mitigate the risks associated with the re-export of this equipment to Russia.

EU entities are also required to include contractual provisions to guarantee that “industrial know-how” transferred to third countries will not be subsequently used for goods transferred to Russia.

IV. Measures concerning the financial sector

The 14^th package reinforces financial sanctions by prohibiting EU operators from using the financial messaging system (SPFS) developed by the Central Bank of Russia.

The Council of the EU is now authorized to compile a list of non-Russian third-country banks connected to SPFS, which will be prohibited from conducting business with EU operators.

Finally, this 14th package bans transactions with banks and crypto asset providers in Russia and third countries that facilitate transactions supporting Russia’s defense-industrial sector.

V. Funding of political parties and other organisations

EU political parties, foundations, NGOs, and think tanks are prohibited from accepting funding from the Russian Federation. However, media service providers are still authorised to carry out research and interviews in the EU apart from broadcasting.

VI. Measures relating to transport

Air transport

The 14th sanctions package now bans all non-scheduled flights organised by Russian individuals or entities. However, this ban does not apply to an aircraft that is simply piloted by a Russian person, or to non-professional flights for recreational or training purposes.

Road transport

Reinforcement of the ban on EU companies in which Russian entities or individuals own 25% or more of the capital from carrying out road haulage operations throughout the EU, including transit. The ban does not apply to road transport companies owned by dual nationals or Russian nationals with a temporary or permanent residence permit in EU Member State.

Maritime transport

The EU has published a list of vessels that are now banned from accessing European ports and receiving services in EU territory. This list is subject to change. To date, 27 ships have been targeted for their involvement in transporting military equipment for Russia, moving stolen Ukrainian grain and supporting the Russian energy sector, in particular by transporting liquefied natural gas (LNG) components or LNG transhipments.

VII. Trade-related measures

This new package of sanctions strengthens export restrictions against 61 entities (notably in China, Kazakhstan, Kyrgyzstan, Turkey and the United Arab Emirates) accused of supporting Russia’s military-industrial complex. It also extends the list of restricted items to include specific machine tools, vehicles, chemicals and electronic equipment.

Imports of helium from Russia are now banned.

The import of Ukrainian cultural property and other goods from Ukraine is now prohibited.

EU nationals and companies can now claim compensation for damages caused by Russian individuals or entities due to the implementation of sanctions.

VIII. Measures relating to protection of intellectual property rights

New restrictive measures limit applications for registration of certain intellectual property rights within the EU by Russian individuals and entities.

IX. Clarifications and amendments on the ban on diamonds

EU regulations specify the measures relating to the ban on imports of Russian diamonds (resulting from the 12^th sanctions package). The ban does not apply to diamonds that were already in the EU or in a third country (excluding Russia) or that were cut or manufactured in a non-EU country before the ban came into force.

The present package extends the transition period for the mandatory system of full traceability of imports of rough and cut natural diamonds by six months, until 1st March 2025 It also postpones the entry into force of the ban on jewellery containing Russian diamonds processed in non-EU countries other than Russia, until the Council of the EU decides to apply the ban in the light of the measures taken by the G7.

X. Measures concerning services to EU nationals and entities

Since the ^12th sanctions package, EU nationals and entities are prohibited from providing accounting, business and management consultancy, market research and software services to a Russian entity, except if

(i) it is a subsidiary in Russia of an EU entity, and
(ii) an individual authorisation has been obtained from the Direction Générale du Trésor (DGT) for France

The 14^th sanctions package extended the deadline for obtaining this individual authorisation to the 30th of September 2024 and specified that it is not necessary for the EU nationals residing in Russia prior to the 24th of February 2022.

Our team remains at your disposal for any question.

Alert: EU adopts 14th package of sanctions against Russia

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