25 July 2022

On 21 July 2022 the EU Council adopted further Russia sanctions, including its “maintenance and alignment” sanctions package. The new Regulations/Council Decisions that introduce these sanctions can be found here and here.

In summary, the new sanctions package (the “seventh sanctions package”) includes:

• A new prohibition to purchase, import, or transfer, directly or indirectly, gold, if it originates in Russia and it has been exported from Russia into the EU or to any third country. This prohibition also covers jewellery.
• An extended list of controlled items, which may contribute to Russia’s military and technological enhancement or the development of its defence and security sector
• An extension of the existing port access ban to locks.
• A number of clarifications to existing measures, for instance in the field of public procurement, aviation and justice.

In addition to the sanctions above, the new sanctions package lists additional individuals and entities and strengthens reporting requirements, putting the burden of declaring assets onto sanctioned people, in order to facilitate the freezing of their assets in the EU.

Prohibition of the export, import or transfer of gold and other controlled items

The new package of sanctions prohibits the purchase, import or transfer (directly or indirectly) of Russia-origin gold (including jewellery) if it has been exported from Russia into the EU or to any third country.

Furthermore, it extends the list of controlled items which might contribute to Russia’s military and technological enhancement or the development of its defence and security sector.

An extension of the existing port access ban to locks.

The new package of sanctions extends the existing port access ban to locks to avoid the circumvention of sanctions...

The sharing of technical assistance with Russia

The new package of sanctions allows the sharing of technical assistance with Russia for aviation goods and technology insofar as it is needed to safeguard the technical industrial standard setting work of the International Civil Aviation Organisation...

New individuals and entities added to the EU’s Russia sanctions list

The new package of sanctions adds 48 people and 9 entities to the EU’s Russia sanctions list, including Sberbank, senior members of the political or cultural establishment, high ranking military leaders and staff, Nightwolves and some of its members, propagandists and leading businesspersons.

Furthermore, it obliges designated people / entities with assets within a Member State jurisdiction to report these assets and to cooperate with the competent authority in the verification of this reporting...

Adjustments to licensing grounds in relation to dual use and critical industry lists controls

The exemption grounds in article 2 and 2a have been amended by removing the exemption for ensuring cyber security and information security. The exemption has been replaced by a case-by-case licensing ground 4(h).

Adding medical or pharmaceutical purposes in  grounds for Annex XXIII items

An additional licensing ground focusing on medical or pharmaceutical purposes has been added in article 3k(5). The previous licensing grounds were limited to humanitarian purposes...