February, 2024 – EU adopts thirteenth package of sanctions against Russia

On 23rd February, 2024, the EU adopted a 13^th package of sanctions against Russia. The legislation implementing this latest package of sanctions can be found here.

The package, which was released shortly after the two year anniversary of the start of the Russia-Ukraine conflict, is focused on further limiting Russia’s access to military technologies. It is also an unprecedented package in terms of the volume of additional designations made; a further 106 individuals and 88 entities have been added to the EU sanctions list, meaning that the number of listed entities now exceeds 2000. 

The UK and US have also updated their own sanctions lists.

Many of the restrictions are not directly relevant to Members. In summary, however, the new sanctions package includes:

• An expansion of the list of entities which are subject to tighter export restrictions on dual-use goods and technologies.
• Additions to the list of restricted items to include components for unmanned aerial vehicles (UAV).
• The addition of the UK to the list of partner countries which apply a set of restrictive measures on imports of iron and steel from Russia. This aligns the UK’s measures with EU import control standards and is designed to foster international cooperation.

Members are reminded that EU sanctions apply within the territory of the European Union, on board any ship under the jurisdiction of an EU Member State; to any person inside or outside the territory of the EU who is a national of a Member State; to any legal person, entity or body, inside or outside the territory of the EU, which is incorporated or constituted under the law of a Member State and to any legal person, entity or body in respect of any business done in whole or in part within the EU.

The sanctions position is constantly changing. As such, it is important that Members undertake thorough due diligence in respect of any contractual counterparts and commercial arrangements involving Russia.

As always, if Members have any questions in relation to the above issues they are invited to contact the Club for further information.