FINANCIAL SANCTIONS GUIDANCE (RUSSIA)

On 9 March 2022, the EU published a further set of measures. These include:

• Introduction of further restrictions on the export of maritime navigation goods and technology;
• Expansion of the list of legal persons, entities and bodies subject to the prohibitions related to investment services, transferable securities, money market instruments, and loans;
• Further clarification (in respect of previous restrictive measures) that “transferable securities” includes crypto-assets.
• Limiting the financial inflows from Belarus to the Union, by prohibiting the acceptance, from Belarusian nationals or residents, of deposits exceeding certain values; the holding of accounts of Belarusian clients by the Union central securities depositories; and the selling of euro-denominated securities to Belarusian clients;
• Exemptions under the sanctions measures, for Swiss, EU and EEA nationals in Belarus, in that deposits exceeding €100,000 can be accepted from them.
• Introduction of clarifications on the exception for the provision of financing for small and medium-sized enterprises, as well as certain provisions in the Annexes, relating to prohibited goods and technology;
• Adding 146 members of the Russian Federation Council to the sanctions list, as those individuals ratified the government decisions of the ‘Treaty of Friendship, Cooperation and Mutual Assistance’ between Russia and the two break-away regions in Donetsk and Luhansk;
• Adding 14 persons to the sanctions list, as they supported and benefited from the Government of the Russian Federation and/or provided substantial revenue to it; or are associated with listed persons or entities.
• Prohibition on the listing and provision of services, on Union trading venues, in relation to shares of Belarus State-owned entities;
• Prohibition on transactions with the Central Bank of Belarus;
• Restrictions on the provision of specialised financial messaging services (SWIFT) to certain Belarusian credit institutions and their Belarusian subsidiaries. These are:
  • Belagroprombank
  • Bank Dabrabyt
  • Development Bank of the Republic of Belarus
• Additional obligations on the Network Manager for air traffic management network functions of the single European Sky, particularly that the Manager rejects all flight plans that violate the Regulations;
• Further clarification (in respect of previous restrictive measures) that “transferable securities” includes crypto-assets.

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The measures that came into force on 15 March include:

• adding another 15 individuals and 9 entities to the list of those subject to asset freezes and travel bans.

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The measures that came into force on 16 March include:

• a ban on credit ratings agencies from providing ratings on Russian Federation debt.

• further trade restrictions concerning iron and steel, as well as luxury goods;

• expanding the list of persons connected to Russia’s defense and industrial base, to apply tighter export restrictions on dual-use goods and technology. A total of 81 persons and entities have been added;

• prohibitions on new investments in the Russian energy sector and export restrictions on related equipment, technology and services, with the exception of nuclear industry and energy transport;

• a ban on all transactions with certain State-owned enterprises which are already subject to refinancing restrictions. A total of 13 companies are listed;

• a ban on the provision of insurance and reinsurance to any legal person, entity or body operating in the energy sector in Russia;

• Derogations have been provided for activities necessary for ensuring critical energy supply within the EU, as well as the transport of fossil fuels, in particular coal, oil and natural gas, from or through Russia into the EU; and where humanitarian considerations arise.

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The measures that come into force on 8 April 2022 include:

• A prohibition on being a beneficiary, acting as a trustee or in similar capacities for Russian persons and entities, as well as a prohibition on providing certain services to trusts has been introduced.
• An import ban on coal from Russia from 10 August 2022;
• A full transaction ban on four key Russian banks. These four banks will now be fully excluded from the EU market. The banks affected are Otkritie, Novikombank, Sovkombank and VTB;
• A ban on any vessel registered under the flag of Russian from accessing EU ports. This includes yachts and recreational craft. Some derogations are granted for the transport of medical, pharmaceutical, agricultural and food products, humanitarian aid, energy and other products as set out in the Regulations;
• A ban on Russian and Belarusian road transport operators traveling the European Union, Switzerland, EEA and western Balkans, limiting their access to key goods;
• Further targeted export bans on items such as quantum computers and advanced semiconductors, sensitive machinery and transportation equipment;
• Specific new import bans on a range of goods as well closing loopholes between Russia and Belarus. This will be achieved by sanctioning certain individuals and entities used to bypass previous sanctions;
  • A €10,000 limit on crypto asset transactions;
• Securities in all EU Member State currencies will now be banned from sale to Russia/Belarus and Russian/Belarusian entities;
• A general EU ban on participation of Russian companies accessing public procurement in Member States;
• An exclusion of all financial support at a national and European Union level to Russian public bodies; and
• Listing of an additional 216 individuals who are Russian, members of 'the People’s Council' of the Donetsk and Luhansk breakaway republics as well as 18 new entities. The list also includes Oleg Deripaska and the 2 daughters of Vladimir Putin.

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Measures introduced 7 June 2022

In light of Russia’s continuing war of aggression against Ukraine and Belarus' support to it, as well as the reported atrocities committed by Russian armed forces in Ukraine, the Council decided today to impose a sixth package of economic and individual sanctions targeting both Russia and Belarus.

The agreed package includes a series of measures intended to effectively thwart Russian abilities to continue the aggression.

Oil

The EU decided to prohibit the purchase, import or transfer of crude oil and certain petroleum products from Russia into the EU. The phasing out of Russian oil will take from 6 months for crude oil to 8 months for other refined petroleum products.

A temporary exception is foreseen for imports of crude oil by pipeline into those EU member states that, due to their geographic situation, suffer from a specific dependence on Russian supplies and have no viable alternative options.

Moreover, Bulgaria and Croatia will also benefit from temporary derogations concerning the import of Russian seaborne crude oil and vacuum gas oil respectively.

De-SWIFTing of additional Russian and Belarusian banks

The EU is extending the existing prohibition on the provision of specialised financial messaging services (SWIFT) to three additional Russian credit institutions - Russia's largest bank Sberbank, Credit Bank of Moscow, and Russian Agricultural Bank - and the Belarusian Bank For Development And Reconstruction.

Broadcasting

The EU is suspending the broadcasting activities in the EU of three more Russian state-owned outlets: Rossiya RTR/RTR Planeta, Rossiya 24 / Russia 24 and TV Centre International. These structures have been used by the Russian Government as instruments to manipulate information and promote disinformation about the invasion of Ukraine, including propaganda, with the aim to destabilise Russia's neighbouring countries and the EU and its member states. In line with the Charter of Fundamental Rights, these measures will not prevent those media outlets and their staff from carrying out activities in the EU other than broadcasting, e.g. research and interviews.

Export restrictions

The EU is expanding the list of persons and entities concerned by export restrictions regarding dual-use goods and technology. Such additions to the list include both Russian and Belarusian entities. Moreover, the EU will expand the list of goods and technology which may contribute to the technological enhancement of Russia’s defence and security sector. This will include 80 chemicals which can be used to produce chemical weapons.

Consulting services

The EU will prohibit the provision of accounting, public relations and consultancy services to Russia.

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On 21 July, the European Union published a new set of restrictive measures in relation to Russian actions in Ukraine. Measures Include:

• The current packages of sanctions have been extended for an additional 6 months, until the end of January 2023;
• The import of Russian origin gold is prohibited from 22^nd July 2022 onwards;
• An additional 51 items have been added to the export control list, mostly from the industrial and advanced technology sectors;
• An additional 48 individuals and 9 entities are subject to an asset freeze, including Sberbank and Credit Bank of Moscow (which are already removed from Swift messaging system;
• The acceptance of deposits of €100,000 from any Russia national/resident, or Russian/Russian resident controlled (50% or more) entity or body from anywhere outside the EU, is now prohibited.
• Prior authorisation required for accepting deposits needed when trading non-prohibited items between the EU and Russia.
• Clarification that Russian ships cannot dock at canal locks in order to circumvent the ban on entering EU ports;

In addition to this package, new restrictive measures have also been introduced against military forces that have been aiding (directly and indirectly) the military actions of Russia in Ukraine. These measures add 6 Syrian individuals and 1 Syrian entity to an asset freeze and travel ban list.

More details

Please find below details of the most recent measures imposed In light of the escalating war and illegal annexations in Ukraine. These measures include:

• Extending the list of restricted items which might contribute to the Russian Federation’s military and technological enhancement or to the development of its defence and security sector, by including in that list certain chemical substances, nerve agents and goods which have no practical use other than for capital punishment, torture or other cruel, inhuman or degrading treatment or punishment, or which could be used for those purposes
• Prohibiting the sale, supply, transfer or export of firearms, their parts and essential components and ammunition
• Extending the import ban on steel products that either originate in the Russian Federation or have been exported from it
• Applying an import ban on wood pulp and paper, certain elements used in the jewellery industry such as stones and precious metals, certain machinery and chemical items, cigarettes, plastics and finished chemical products such as cosmetics. This also includes items which could contribute to the enhancement of Russian industrial capacities and restrictions are imposed on the sale, supply, transfer or export of additional goods used in the aviation sector
• introducing an exemption from the prohibition to provide technical assistance, brokering services or financing or financial assistance, related to the maritime transport to third countries of crude oil or petroleum products which originate in or are exported from Russia, purchased at or below a pre-established price cap agreed by the Price Cap Coalition
• Expanding the prohibition to engage in any transaction with certain Russian State-owned or State-controlled legal persons, entities or bodies by including a ban on EU nationals to hold any posts on the governing bodies of those legal persons, entities or bodies
• Applying a transaction ban on the Russian Maritime Register of Shipping
• Extending the port access and lock ban in the territory of the EU to vessels certified by the Russian Maritime Register of Shipping
• Removing the threshold for the existing prohibition on the provision of crypto-asset wallet, account or custody services to Russian persons and residents, thereby banning the provision of such services regardless of the total value of such crypto-assets
• Extending the existing prohibition on the provision of certain services to the Russian Federation by banning the provision of architectural and engineering services as well as of IT consultancy services and legal advisory services
• Adding 30 persons and seven entities to the list of those subject to a travel ban and asset freeze

More details

• An additional 141 persons and 49 entities have been added to the list of those subject to asset freezes and travel bans. This brings the total to 1,382 individuals and 167 entities targeted through the Russian sanctions list.
• All financial transactions with the Russian Regional Development Bank by EU citizens and entities are banned. Dalnevostochny Bank and Credit Bank of Moscow are now subject to an asset freeze.
• Additional goods and services have been restricted such as chemicals, riot control agents, electronic components found in Russian weapon systems, UAV/drone components and low-tech goods (generators, laptops, hard-drives). Also, certain goods and services for the space and aviation industries, such as airplane engines and their parts, can longer be provided to Russia, this includes engines utilized in unmanned aerial vehicles.
• The ban on providing services to Russia is extended to include advertising, product testing and technical inspection services. The current ban for EU citizens and entities investing in certain sectors is now extended to include the Russian mining sector. These sectors are being targeted in order to hinder the economic activity of Russia which is financially sustaining its invasion of Ukraine.
• NTV/NTV Mir, Rossiya 1, REN TV and Pervyi Kanal will lose their licenses to broadcast in the EU as of 16 December 2022. They will, however, be able to continue other activities such as research and interviews, which are protected by the Charter of Fundamental Rights.
• The current ban on EU nationals sitting on the boards of Russian companies is extended to include all Russian State-owned companies; at the same time, Russians (nationals and residents) are prohibited from holding roles in EU companies which manage or own critical infrastructure. 
• New measures have been introduced to ensure there is alignment on the reporting obligations of all credit institutions across all Member States.

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Tenth package of sanctions in response to Russia’s invasion of Ukraine

The Council adopted new restrictive measures against Russia. The agreed package includes bans on:

• exports of critical technology and industrial goods
• imports of asphalt and synthetic rubber
• provision of gas storage capacity to Russians
• transit through Russia of EU exported dual use goods and technology

The EU has also:

• suspended the broadcasting licenses of RT Arabic and Sputnik Arabic
• restricted the possibility for Russian nationals to hold any position in the governing bodies of EU critical infrastructures and entities
• introduced new reporting obligations to ensure the effectiveness of the asset freeze prohibitions
• imposed additional sanctions against 87 individuals and 34 entities, including key decision makers, military leaders, military commanders of the Wagner group and drone manufacturers

• EU adopts its 10th package of economic and individual sanctions (press release, 25 February 2023)
• EU includes additional 87 individuals and 34 entities to the sanctions list (press release, 25 February 2023)

Eleventh package of sanctions in response to Russia’s invasion of Ukraine

The Council adopted new restrictive measures against Russia. The agreed package includes amongst others, measures to:

• strengthen bilateral and multilateral cooperation with third countries to impede sanctions’ circumvention
• prohibit the transit of goods and technology via Russia
• tighten export restrictions

The EU has also:

• imposed additional sanctions against 71 individuals and 33 entities

• Russia's war of aggression against Ukraine: EU adopts 11th package of economic and individual sanctions (press release, 23 June 2023)
• 11th package of sanctions on Russia' war of aggression against Ukraine: additional 71 individuals and 33 entities included in the EU's sanctions list and new tools to counter circumvention and information warfare (press release, 23 June 203)

Twelfth package of sanctions in response to Russia’s invasion of Ukraine

• Additional listing of over 140 individuals and entities to the sanctions list.
• A ban on direct or indirect import, purchase or transfer of diamonds from Russia.
• A direct ban applies to non-industrial natural and synthetic diamonds.
• Introduction of a no Russia clause which prohibits re-exportation to Russia of particularly sensitive goods and technology, including Russian military systems.
• Further circumvention measures relating to dual use goods and technologies, including extending the transit ban to all battlefield goods.
• Exceptions were introduced for personal use items.
• A ban on Russian nationals from holding any posts on governing bodies.
• Tighter compliance rules have been introduce to clamp down on circumvention to support the implementation of the oil price cap.

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13^th package of restrictive measures imposed In light of the continuing war in Ukraine.

This is an unprecedented package of 194 individual designations, including 106 individuals and 88 entities. With it, the EU exceeds the threshold of 2000 listings. In particular:

• Targeting Russia's military and defence sector: the new listings include more than 140 companies and individuals from the Russian military-industrial complex, which among other things manufacture missiles, drones, anti-aircraft missile system, military vehicles, high-tech components for weapons, and other military equipment.
• Sending a strong signal against Russia's war effort partners: the new listings target 10 Russian companies and individuals involved in the shipping of Democratic People's Republic of Korea (DPRK) armaments to Russia. They also target the Defence Minister of the DPRK, as well as several Belarusian companies and individuals providing support to the Russian armed forces.
• Fighting circumvention: the new listings include a Russian logistics company and its director involved in parallel imports of prohibited goods to Russia, and a third Russian actor involved in another procurement scheme.
• Strengthening EU action against Russia's temporary occupation and illegal annexation of areas of Ukraine: the new listings include six judges and 10 officials in the occupied territories of Ukraine.
• Sanctioning violations of children rights: The new listings also include 15 individuals and 2 entities involved in the forced transfer and in the deportation and the military indoctrination of Ukrainian children, including in Belarus.

The Department of Finance asks that all entities familiarise themselves with the measures introduced and how they can comply with the sanctions. The relevant Statutory Instruments are, or will be shortly, available on the Irish Statute Book. Further information on restrictive measures can be viewed also at:

• The EU Council website, from which the measures agreed at an EU level in response to the crisis in Ukraine can be found
• The European Commission website, from which Frequency Asked Question documents are available
• The Central Bank of Ireland
• D/Foreign Affairs – who also have domestic guidance on the implementation of sanctions at the bottom of that page.

Please monitor the websites referenced above closely in the event that further information is available or further restrictive measures are adopted. 

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