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Questions and Answers: tenth package of restrictive measures against Russia

Met dank overgenomen van Europese Commissie (EC), gepubliceerd op zaterdag 25 februari 2023.


Who have you targeted?

120 individuals and 96 entities added to the sanctions list, including Russian decision-makers, senior government officials, military leaders complicit in the war against Ukraine, as well as proxy authorities installed by Russia in the occupied territories in Ukraine, amongst others. The list also includes key figures involved in the kidnapping of Ukrainian children to Russia, as well as organisations and individuals who are polluting the public space with disinformation, adding to the military warfare through information warfare.

Measures are also taken against individuals in Iran who are involved in the elaboration of drones and components supporting Russia's military. In addition, members and supporters of Russia's Wagner mercenary group and its activities in other countries, such as Mali or Central African Republic, are also targeted.

Financial sector

Three additional Russian banks have been sanctioned (asset freeze). The listing has a deep impact on the day-to-day business of listed banks, cutting them off from the EU economy and financial system.

Critical infrastructure, gas storage

Why have you imposed a ban on Russian nationals serving on boards of critical infrastructure companies in the EU, such as electricity grids or gas providers?

Critical infrastructures and entities are providers of essential services. Having Russian nationals in governing bodies of such entities may threaten their well-functioning and the security/safety of EU citizens, as well as the security interests of the EU.

Why have you banned Russian nationals and entities from booking gas capacity in gas storages in the EU?

EU gas storage plays a key role in ensuring the energy supply of the EU. This measure aims at countering the Russia's weaponisation of its gas supply and to avoid risks of market manipulation by Russian operators that would be detrimental to the critical energy supply of the Union. LNG is explicitly excluded from this measure.

Import and export restrictions

What new import and export restrictions have been introduced?

With the 10th package of sanctions against Russia, we have introduced new measures concerning both export (value of export bans EUR 11.4 billion) and import (value of import bans EUR 1.3 billion).

On the export side, we have continued to target goods and technologies particularly relevant for the Russian military and industrial complex and, on the import side, goods that generate significant revenue for Russia.

Additional trade bans on imports into the EU of Russian synthetic rubber and asphalt or bitumen (an oil product) and on exports into Russia of EU industrial goods and goods that can be easily redirected to be used to support the Russian war effort including trucks, other heavy vehicles, construction machines, pumps and other machines used in the construction sector.

The package also includes additional export restrictions on sensitive dual-use and advanced technology items that could contribute to Russia's military capabilities and technological enhancement, based on information retrieved from Russian military systems on the battlefield. Moreover, we are also listing 96 additional entities associated to Russia's military-industrial complex, bringing the total of military end-users that are listed to 506. This includes for the first time seven Iranian entities that have been using EU components and providing Russia with military "Shahed" drones to attack civilian infrastructure in Ukraine. This should act as a strong deterrent to other companies and international traders that circumvention of export restrictions will not be tolerated. Importantly, we are working in close coordination with partners and are adding Australia, Canada and New Zealand and Norway to the list of our partner countries.

A third country shipping company, suspected of helping Russia circumvent sanctions on oil exports, has also been listed.

What other trade-related measures are included in this package?

Furthermore, a new full export ban is placed on turbojets and their parts, therefore reinforcing the existing ban on aircrafts, their engines and parts.

Anti-circumvention measures

We have introduced a transit ban for dual-use goods and advanced technology and firearms via the Russian territory. This means that goods can no longer transit via the territory of Russia when exported to third countries.


Why has the EU added further outlets to the sanctions list?

We have added Arab language subsidiaries of RT (Russia Today) and Sputnik because they are Russian state-owned and/or under the Kremlin's influence and they disseminate disinformation and war propaganda of the sanctioned regime, aiding Russia's war efforts.


Which clarifications did the EU introduce?

We have clarified when and under which conditions, goods can be considered as imported into the Union when such goods were physically in the Union and already presented to customs authorities when they become subject to import restrictions. Such a clarification was necessary for Union operators which brought those goods into the Union in good faith at a time when they were not yet subject to any import restrictive measures.

Reporting obligations

What reporting obligations have been proposed and why?

The new measures introduced the following changes to the reporting obligations:

  • In Regulation 269/2014 (asset freeze), more detailed reporting obligations on frozen assets (including for dealings before listings) and assets which should be frozen. Operators are required to report this information to Member States, which in turn are required to report it to the Commission.

Central securities depositories report to Member States and also directly to the Commission to streamline the reporting process at EU-level.

These changes, including further details on what information should be provided, are aimed at ensuring a uniform application of the asset freeze provisions.

  • In Regulation 833/2014 (sectoral sanctions), new reporting obligations for the operators to the Member States and the Commission on assets and reserves of the Central Bank of Russia, which they hold or control or are a counterparty to.

These changes are aimed at ensuring a uniform application of the prohibition of transactions related to the management of reserves and assets of the Central Bank of Russia.

Under the new provisions, Member States and EU operators will have to cooperate with the Commission in the verification of the information provided and the Commission may request any additional information.


What is the rationale of imposing such sanctions?

Sanctions are targeted at the Kremlin. They aim to weaken the Russian government's ability to finance its war of aggression against Ukraine and are calibrated in order to minimise the negative consequences on the Russian population.

Sanctions are imposing a direct cost on Russia for its war of aggression and damaging Russia's industrial and economic ability to wage war, manufacture more weapons, and repair existing weapons systems. The sanctions also deprive the Russian army and its suppliers of the goods and equipment needed to wage its war against Ukraine.

In addition, sanctions are designed to maximise the negative impact for the Russian economy, while limiting the consequences for EU businesses and citizens. We welcome EU companies' diligence in complying with the sanctions framework in place.

Ensuring an effective and diligent implementation of sanctions is key to prevent circumvention. This is primarily the responsibility of Member States.

In this process, the European Commission is fully committed to assisting them and ensuring a consistent implementation across the Union.

Are EU sanctions aggravating the global food crisis?

No. It is Russia's unprovoked invasion of Ukraine and Russia's deliberate actions - such as limiting grain exports from Ukraine, burning crops and silos, stealing Ukrainian cereals, and complicating trade - that is provoking a global food crisis.

None of the EU's sanctions adopted against Russia prevent the supply of agri-food, medical equipment or medicines for the general population. Agricultural machinery per se is also not subject to any export ban.

None of the sanctions adopted by the EU in view of Russia's war of aggression against Ukraine target the trade in agricultural and food products, including cereals and fertilisers, between third countries and Russia.

Available data from the UN indicate that the Russian exports of grains and fertilisers in 2022 remained quite stable compared with previous years.

If third countries wish to buy Russian fertilisers, there are no EU sanctions that would prohibit this.

On 19 September 2022, the EU issued updated guidance to clarify the situation in which EU operators transport a sanctioned item to a third country. It makes it clear that the transfer of Russian fertilisers to third countries via the EU is permitted. Given the food security concerns in certain third countries, the 9th package of sanctions introduced a targeted derogation allowing Member States to unfreeze assets of, and to make funds and economic resources available to, certain individuals who held a prominent significant role in international trade in agricultural and food products, including wheat and fertilisers, prior to their listing.

For More Information

Press release: EU agrees 10th package of sanctions against Russia

Official Journal

European Commission website on Ukraine

Q&A on restrictive measures

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