What the EU is doing and why
Since March 2014, the EU has progressively imposed restrictive measures (sanctions) against Russia, initially in response to the illegal annexation of Crimea and Sevastopol and the deliberate destabilisation of Ukraine. On 23 February 2022, the EU expanded the sanctions in response to the recognition of the non-government controlled areas of the Donetsk and Luhansk ‘oblasts’ of Ukraine, and the ordering of Russian armed forces into those areas. After 24 February 2022, in response to Russia’s military aggression against Ukraine, the EU massively expanded the sanctions. It added a significant number of individuals and organisations to the sanctions list, and adopted unprecedented measures with the aim of weakening Russia's economic base, depriving it of critical technologies and markets, and significantly curtailing its ability to wage war.
In parallel, the EU sanctions regime concerning Belarus has been expanded in response to the country’s involvement in Russia’s aggression against Ukraine. This is in addition to the sanctions aimed at Belarus that were already in place. This sanctions regime consists of a range of financial, economic and trade measures.
The respective Council Regulations identified below are addressed to all individuals, organisations and bodies under EU jurisdiction, for which they create legal obligations.
- Consolidated text of Regulation (EU) No 833/2014 (Russia)
- Consolidated text of Regulation (EU) No 269/2014 (Ukraine territorial integrity)
EU sanctions map
The EU sanctions map provides comprehensive details of all EU sanctions regimes and their corresponding legal acts, including a whistleblower tool, a consolidated list of travel bans and a consolidated list of financial sanctions.
The Council adopted a new set of sanctions against Belarus, in view of its involvement in Russia's illegal war of aggression against Ukraine.
The new measures are tailored in view of the specific characteristics of EU-Belarus trade and affect various sectors of the Belarusian economy, including trade, services and transport. This allows for an effective strategy in combating circumvention, while ensuring that the measures are proportionate to the level of Belarus' involvement in Russia’s war of aggression against Ukraine. The new measures enable EU operators to claim compensation for damages caused by Belarusian entities linked to sanctions implementation and expropriation.
The sectoral measures against Belarus were last amended in August 2023 to align them further with the sanctions against Russia.
For more information
The Council adopted a 14th package of restrictive measures designed to target high-value sectors of the Russian economy, like energy, finance and trade, and make it ever more difficult to circumvent EU sanctions.
The 14th package includes the following elements:
Energy-related measures
- Prohibition on providing goods, technology or services to LNG projects under construction in Russia
- Prohibition on the transshipment of Russian LNG through EU ports
- Prohibition on the import of Russian LNG into specific terminals which are not connected to the EU gas pipeline network
- Listings of vessels supporting the Russian warfare
Anti-circumvention measures
- Best efforts obligation concerning foreign subsidiaries: EU companies will have to undertake their best efforts to ensure that their subsidiaries in third countries do not take part in any activities undermining EU sanctions
- “No Russia” clause for Intellectual Property Rights (IPR) transfers, to ensure that industrial know-how transferred outside the Union is not used to manufacture Common High Priority (CHP) goods intended for Russia
- Due diligence requirements for CHP goods
Additional listings
- A total of 116 additional listings of 69 individuals and 47 entities subject to asset freezes, and – in the case of individuals – also to travel bans. Listings touch upon various sectors of the Russian state, including military companies, companies active in space engineering, in the chemical sector or in the explosives sector and leading Russian energy companies. The listings include actors involved in disinformation/propaganda activities, in support of Russia’s war of aggression against Ukraine
Financial sector measures
- Prohibition for EU banks outside Russia to connect and carry out transactions using the Financial Messaging System of the Central Bank of Russia (SPFS)
- Prohibition on transactions with third-country banks using SPFS to increase Russia’s financial resilience and to support the circumvention of our sanctions
- Prohibition on transactions with banks and crypto assets providers, in Russia and third countries, that facilitatetransactions supporting Russia’s defence-industrial base
Trade-related measures
Exports
- Extension of the export restrictions on dual use/advanced technology items (e.g., “quadbikes”, microwave and aerial amplifiers and digital flight data recorders)
- Reinforcement of the current export bans on industrial goods focusing on four sectors which are key to Russia’s war economy: chemicals, plastics, vehicles parts and machinery, worth EUR 5 billion of annual exports prior to the invasion (2021)
Imports
- Import ban on helium
- Finetuning of the import ban on Russian diamonds
- Addition of 61 Russian and third-country entities to the list of entities associated to Russia's military-industrial complex (including 33 entities registered in third countries: 19 in China/Hong Kong, 9 in Türkiye, 2 in Kyrgyzstan, 1 in India, 1 in Kazakhstan, 1 in UAE)
- Extension of the Common High Priority (CHP) list
Transport measures
- Aviation:prohibition on non-scheduled flights if a Russian person decides the origin or destination (regardless of ownership and control over the aircraft); introduction of uniform obligation to provide information about non-scheduled flights upon request of national authorities regarding aircraft ownership, passengers etc., also to avoid circumvention of the flight ban
- Road:tightening the existing prohibition to transport goods by road in the EU
- Maritime: prohibition on port access and services for listed vessels. In the 14th package, 27 vessels are placed on this list, for their contribution to the Russian warfare in various sectors such as the transport of military equipment for Russia and the transport of stolen Ukrainian grain, participation in the dark fleet transporting Russian oil while conducting deceptive shipping practices, and support in the development of Russia’s energy sector, for instance through the transport of LNG infrastructure components or LNG transshipments
Protection of EU operators
- Legal basis for compensation claims in Member States courts: creation of a legal basis for EU operators to claim compensation in the EU for damages caused by Russian companies linked to sanctions implementation and expropriation
- Transaction ban to protect arbitration
Measures protecting intellectual property rights (IPR)
- Prohibition on the acceptance, by EU and Member States’ intellectual property offices and authorities, of applications for registration of, among others, new trademarks and patents requested by Russian persons and persons resident in Russia
Measures combatting Russian interference
- Prohibition on accepting financing from the Russian state and its proxies by political parties, NGOs and media service providers in the EU
Additional measures
- Prohibition on EU and Member States funding to all Russian entities – and not only state-owned ones as was previously the case. This would align with already existing restrictions on public procurement
- Import ban on stolen Ukrainian cultural items: for cultural heritage products stolen from Ukraine
For more information
The Council of the European Union adopted the following additional measures:
The suspension of the broadcasting activities of four more media outlets - Voice of Europe, RIA Novosti, Izvestia, and Rossiyskaya Gazeta - in the EU or directed at the EU, in view of their role supporting and justifying Russia's war of aggression against Ukraine.
For more information
The Council of the European Union adopted the following additional measures
Additional listings
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
Trade measures
This package further deepens our actions to stop Russia from acquiring Western sensitive technologies for Russian military. Unmanned aerial vehicles, or drones, have been central to Russia's war against Ukraine. This package thus specifically lists companies procuring Russia with key drone components and introduces some sectoral sanctions to close loopholes and make drone warfare more complicated.
Based on hard evidence from various sources, supported by trade and customs data, the package adds 27 Russian and third country companies to the list of entities associated to Russia's military-industrial complex (Annex IV of Regulation 833/2014). The EU will impose export restrictions towards these companies regarding dual-use goods and technology, as well as goods and technology which might contribute to the technological enhancement of Russia's defence and security sector. The package adds
- 17 Russian companies which are involved in the development, production and supply of electronic components, particularly used in connection with drone production
- Four companies registered in China and one each registered in Kazakhstan, India, Serbia, Thailand, Sri Lanka, and Türkiye, also trading in the area of electronic components, including of EU-origin
In addition, the package expands the list of advanced technology items that may contribute to Russia's military and technological enhancement or to the development of its defence and security sector. It adds components used for the development and production of drones, such as electric transformers, static converters and inductors found inter aliain drones, as well as aluminium capacitors, which have military applications, such as in missiles and drones and in communication systems for aircrafts and vessels. This will further weaken Russia's military capabilities.
Measures to foster international cooperation
The new package adds the United Kingdom to the list of partner countries for the iron and steel imports. These partner countries apply a set of restrictive measures on imports of iron and steel and a set of import control measures that are substantially equivalent to those in the EU Regulation (EU) No 833/2014.
For more information
The Council of the European Union adopted the following additional measures
Additional listings
- Over 140 additional individuals and entities subject to asset freezes. This covers actors in the Russian military and defence, including military industry companies and Private Military Companies. This also includes actors from the IT sector, as well as other important economic actors. The measures also target whose who have orchestrated the recent illegal so-called “elections” in the territories of Ukraine that Russia has temporarily occupied, and those responsible for the forced “re-education” of Ukrainian children, as well as actors spreading disinformation/propaganda in support of Russia's war of aggression against Ukraine
Trade measures
- Import ban on Russian diamonds: import restrictions on non-industrial diamonds, mined, processed, or produced, in Russia. These proposed sanctions are part of an internationally coordinated G7 diamond ban, aiming to deprive Russia of this important revenue stream estimated at €4 billion per year. All G7 members will implement a direct ban on diamonds exported from Russia at the latest by 1 January 2024. As of 1 March 2024, a ban on Russian diamonds polished in a third country will take effect and, as of 1 September 2024, the ban will be expanded to include lab-grown diamonds, jewellery, and watches containing diamonds. To further the effectiveness of these measures, a robust traceability-based verification and certification mechanism for rough diamonds will be established within the G7
- Import ban on raw materials for steel production, processed aluminium products and other metal goods: new measures restricting imports from Russia of certain metal goods
- Export restrictions: additional export restrictions on dual-use and advanced technological and industrial goods worth €2.3 billion per year
- New export controls on dual use/advanced tech, aiming to further weaken Russia's military capabilities, including chemicals, thermostats, DC motors and servomotors for unmanned aerial vehicles (UAV), machine tools and machinery parts
- New export bans on EU industrial goods, to further hamper Russia's capacities in its industrial sector, including machinery and parts, construction-related goods, processed steel, copper and aluminium goods, lasers, and batteries
- Addition of 29 Russian and third country entities to the list of entities associated to Russia's military-industrial complex (including entities registered in Uzbekistan and Singapore)
- Prohibition to provide enterprise and design-related software to the Russian government or Russian companies. The aim is to further hamper Russia's capacities in its industrial sector. Restrictions in the area of services are an area where we have worked closely with our international partners, including the US and the UK
Stricter asset freeze obligations
- New listing criterion: The Council has agreed a new listing criterion to include persons who benefit from the forced transfer of ownership or control over Russian subsidiaries of EU companies. This will ensure that no one profits from the losses that EU companies face when their subsidiaries are forcibly acquired by Russian owners/management
- Possibility to keep deceased persons on the asset freeze list, in order to prevent the freezing measure from potentially being undermined
- Tighter obligation for Member States to proactively trace assets of listed persons, in order to prevent and detect instances of breach or circumvention of sanctions
Energy measures
- Oil price cap: To make it more difficult for Russia to sustain the war, we have tightened the international G7+ oil price cap, by introducing new measures to more closely monitor the sale of tankers to third countries, as well as require more detailed attestation requirements. This will help to tackle the ‘shadow fleet' used by Russia to circumvent the price cap. In this respect, the EU is in close dialogue with our G7 partners to ensure alignment of our measures and future guidance
- New import ban on liquified petroleum gas (LPG), impacting annual imports worth over €1 billion, with grandfathering of existing contracts for a period of maximum 12 months
Stronger anti-circumvention measures
- Broadening of the scope of the transit prohibition through Russia by adding certain economically critical goods when these are intended for export to third countries
- Obligation for operators to contractually prohibit the re-export of certain categories of sensitive goods to Russia, including goods related to aviation, jet fuel, firearms and goods on the common high priority list
- Introduction of a new measure that will require the notification of certain transfers of funds out of the EU from EU entities directly or indirectly owned by more than 40% by Russians or entities established in Russia
Additional measures
- Introduction of a new derogation to allow for cases in which Member States decide to deprive in the public interest a listed person of funds or economic resources
- Introduction of a derogation to allow compensation for damages to be paid by a newly listed insurance company
- Introduction of a derogation to allow the sale of EU companies owned by certain listed individuals or entities
Other
- Inclusion of a technical amendment allowing for the provision of pilot services necessary for maritime safety
For more information
New measures amend Regulation (EC) 765/2006 concerning restrictive measures in view of the situation in Belarus. These amendments create a closer alignment of EU sanctions targeting Russia and Belarus and will help to ensure that Russian sanctions cannot be circumvented through Belarus.
The measures expand the ban on exports to Belarus to a number of highly sensitive goods and technologies which contribute to Belarus’s military and technological enhancement. The Council also imposes an additional export ban on firearms and ammunition, and on goods and technology suited for use in aviation and the space industry. The changes also align the Belarus sanctions with the Russia sanctions regime.
These restrictive measures are fast-tracked in view of the urgency linked to the fight against circumvention regarding certain highly sensitive goods and technologies. They are without prejudice to the remainder of the proposals presented by the High Representative of the Union for Foreign Affairs and Security Policy and Commission to amend Decision 2012/642/CFSP and Regulation (EC) No 765/2006 on 26 January 2023, which remain on the table.
The Council of the European Union adopted the following additional measures
Trade measures
- New anti-circumvention tool: this will allow the EU to restrict the sale, supply, transfer or export of specified sanctioned goods and technology to certain third countries whose jurisdictions are considered to be at continued and particularly high risk of circumvention. This new “anti-circumvention” tool will be an exceptional and last resort measure when other individual measures and outreach by the EU to concerned third countries have been insufficient to prevent circumvention
- Extension of the transit prohibition for certain sensitive goods (e.g. advanced technology, aviation-related materials) exported from the EU to third countries, via Russia. This will also reduce the risk of circumvention
- Addition of 87 new entities to the list of those directly supporting Russia’s military and industrial complex in its war of aggression against Ukraine. They are subject to tighter export restrictions for dual-use and advanced technology items. In addition to the Russian and Iranian entities already listed, this now also covers entities registered in China, Uzbekistan, the United Arab Emirates, Syria and Armenia
- Restriction on the exports of further 15 technological items found on the battlefield in Ukraine or equipment needed to produce such items. We are working in close coordination with partners and are adding Switzerland to the list of our partner countries
- Tightening restrictions on imports of iron and steel goods by requiring importers of sanctioned iron and steel goods that have been processed in a third country to prove that the inputs used do not come from Russia
- Prohibition to sell, license, transfer or refer intellectual property rights and trade secrets used in connection with restricted goods to prevent the sanctioned goods from simply being manufactured outside the EU
- Extension of the ban on export of luxury cars to all new and second-hand cars above a certain engine size (> 1900 cm3), and all electric and hybrid vehicles
- A full ban on certain types of machinery components
- Simplifying the structure of the industrial goods annex, by listing products subject to restrictions in one single section and with broader product definitions, to better identify goods subject to export bans and reduce circumvention of sanctions by misclassification
Transport measures
- A full ban on trucks with Russian trailers and semi-trailers from transporting goods to the EU. This will clamp down on the circumvention of the prohibition for Russian freight road operator to carry goods in the EU
- Prohibition to access EU ports for vessels that engage in ship-to-ship transfers suspected to be in breach of the Russian oil import ban or G7 Coalition price cap
- Prohibition to access EU ports for vessels if a vessel does not notify the competent authority at least 48 hours in advance about a ship-to-ship transfer occurring within the Exclusive Economic Zone of a Member State or within 12 nautical miles from the baseline of that Member State’s coast
- Prohibition to access EU ports for vessels which manipulate or turn off their navigation tracking system when transporting Russian oil subject to the oil import ban or G7 price cap
Energy measures
- End of the possibility to import Russian oil by pipeline for Germany and Poland
- Insertions of strict and very targeted derogations to the existing export bans to enable the maintenance of the CPC (Caspian Pipeline Consortium) pipeline which transports Kazakh oil to the EU through Russia
- Extension of the exception to the oil price cap for Sakhalin oil for Japan (until 31 March 2024)
Additional listings
- Over 100 additional individuals and entities subject to asset freezes. This includes senior military officials, decision makers on the war, persons involved in the illegal deportation of Ukrainian children to Russia, judges who took politically motivated decisions against Ukrainian citizens, persons responsible for the looting of cultural heritage, businesspersons, propagandists, as well as Russian IT companies providing critical technology and software to the Russian intelligence, banks operating in the occupied territories and entities working with the Russian armed forces
Additional clarifications
- Revision of the listing criterion for individuals/entities engaged in circumventing EU sanctions, including those significantly frustrating EU sanctions
- Addition of a new listing criterion to allow the designation of persons and entities operating in the Russian IT sector with a license from Federal Security Service of the Russian Federation (FSB) or the Russian Ministry of Industry and Trade
- Insertion of a derogation allowing the sale of proprietary rights in a Russian joint venture co-owned with a listed person
- Insertion of a derogation allowing the disposal of certain types of securities held with specified listed entities
- Insertion of certain clarifications in the provision on information sharing between competent authorities and regarding the respect of the confidentiality of the communications between lawyers and their clients in the context of reporting obligations
- Insertion of a derogation allowing the provision of services required for the establishment of a firewall removing the control by a listed person over the assets of an EU entity
- Insertion of an exemption for the provision of pilot services in specific circumstances
Other
- Extension of the media ban to 5 additional channels
- Additional provisions on information exchange and reporting
- Insertion of a temporary derogation to allow for the provision of prohibited services which are legally required for the divestment of Russian operators from the EU
For more information
The Council of the European Union adopted the following additional measures
- Additional listings: The EU has added about 120 individuals and entities to our sanction list, including Russian decision-makers, senior government officials and military leaders complicit in the war against Ukraine, as well as proxy authorities installed by Russia in the occupied territories in Ukraine, among 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.
- Additional EU export bans: New export restrictions have been introduced on sensitive dual-use and advanced technologies that contribute to Russia's military capabilities and technological enhancement, based on information received from Ukraine, our Member States and our partners. This includes additional electronic components used in Russian weapons systems (drones, missiles, helicopters, other vehicles), as well as bans on specific rare earths and thermal cameras with military applications. 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 also 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. 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.
Additional export bans are now also imposed on goods that can be easily redirected to be used to support the Russian war effort including
- vehicles: heavy trucks not yet banned (and their spare parts), semi-trailers, and special vehicles such as snowmobiles
- goods easily directed to the Russian military: including electric generators, binoculars, radars, compass, etc
- construction goods such as bridges, structures for buildings tower-like, fork-lifts trucks, cranes, etc.
- goods that are critical for the functioning and enhancement of Russian industrial capacity (electronics, machine parts, pumps, machinery for working metals, etc.)
- complete industrial plants: this category has been added to avoid loopholes
- goods used in the aviation industry (turbojets)
These new bans and restrictions cover EU exports worth EUR 11.4 billion (2021 data). They come on top of the €32.5 billion worth of exports already sanctioned in the previous packages. With today's package, the EU has sanctioned in total nearly close to half (49%) of its 2021 exports to Russia.
- vehicles: heavy trucks not yet banned (and their spare parts), semi-trailers, and special vehicles such as snowmobiles
- Additional imports bans into the EU: Today's package imposes import bans on the following Russian high-revenue goods
- bitumen and related materials like asphalt
- synthetic rubber and carbon blacks
These new import bans cover EU imports worth almost EUR 1.3 billion and they come on top of €90 billion already sanctioned, representing altogether 58% of the EU's 2021 imports.
- bitumen and related materials like asphalt
- Financial sector: Three Russian banks have been added to the list of entities subject to the asset freeze and the prohibition to make funds and economic resources available.
- Other measures include the following
- a ban on Russian nationals from serving on governing bodies of Member States' critical infrastructure companies
- prohibition on Russian nationals and entities to book gas storage capacity in the Union (LNG excluded)
- measures to facilitate the divestment from Russia by EU operators
A third country shipping company, suspected of helping Russia circumvent sanctions on oil exports, has also been listed.
- a ban on Russian nationals from serving on governing bodies of Member States' critical infrastructure companies
Enforcement and anti-circumvention measures: Today's package imposes new reporting obligations on Russian Central Bank assets. This is especially important regarding the possible use of public Russian assets to fund the reconstruction of Ukraine after Russia is defeated.
Other measures include the following- reporting obligations on frozen assets (including for dealings before listings) and assets which should be frozen
- private flights between the EU and Russia, directly or via third countries, should be notified in advance
- prohibition to transit dual use goods and firearms via the territory of Russia to third countries
In addition to today's package, the EU sanctions envoy David O'Sullivan is reaching out to third countries, to ensure strict implementation of sanctions and prevent circumvention. On 23 February, the first Sanctions Coordinators Forum took place in Brussels, gathering our international partners and Member States, to strengthen enforcement efforts.
- reporting obligations on frozen assets (including for dealings before listings) and assets which should be frozen
Additional bans on Russian disinformation outlets: Two additional Russian media outlets have been added to the media ban.
Technical amendments
- amendment to allow the provision of pilot services necessary for maritime safety
- definition of the term “import” to avoid goods being “stranded” in long customs procedures
- amendment to allow the provision of pilot services necessary for maritime safety
For more information
The Council of the European Union adopted the following additional measures
- Additional listings: The EU has added almost 200 additional individuals and organisations to our list of people subject to a freezing of their assets. This includes the Russian armed forces, as well as individual officers and defence industry companies, members of the State Duma and Federation Council, ministers, Russian proxy authorities in occupied areas of Ukraine and political parties, among others. This list covers key figures involved in in Russia's brutal and deliberate missile strikes against civilians, in the kidnapping and abduction to Russia of Ukrainian children, and in the theft of Ukrainian agricultural products.
- Additional EU export bans: New export restrictions have been introduced on sensitive dual-use and advanced technologies that contribute to Russia's military capabilities and technological enhancement. This includes drone engines, camouflage gear, additional chemical/biological equipment, riot control agents and additional electronic components found in Russian military systems on the battlefield.
- Moreover, the most severe export restrictions have been extended to 168 additional Russian organisations closely linked to the Russian military-industrial complex in an effort to cut off their access to sensitive dual-use and advanced technology items. This brings the total number of organisations sanctioned to 410. This decision has been taken in close collaboration with our partners and includes military end-users working in various sectors such as aeronautics.
- New export bans will extend to additional industrial goods and technology, such as toy/hobby drones, complex generator devices, laptop computers and computing components, printed circuits, radio navigational systems, radio remote control apparatus, aircraft engines and parts of engines, cameras and lenses.
- An even wider range of business services can no longer be provided to Russia with the introduction of bans on market research and public opinion polling services, technical testing and analysis services, and advertising services.
- Additional transactions bans for Russian banks: Three additional Russian banks have been sanctioned, including a full transaction ban on the Russian Regional Development Bank to further paralyse Putin's cash machines.
- Additional bans on Russian media outlets: Four additional Russian channels have been sanctioned in the EU.
- Cutting Russia's access to drones: The direct exports of drone engines to Russia is now restricted, as is the export to any non-EU countries, such as Iran, where there is a suspicion that they will be used in Russia. There are also additional economic measures against the Russian energy and mining sectors.
For more information
The Council of the European Union adopted the following additional measures
- Additional listings: Additional individuals and organisations have been sanctioned. This targets those involved in Russia's occupation, illegal annexation, and sham “referenda” in the occupied territories/oblasts of the Donetsk, Luhansk, Kherson, and Zaporizhzhia regions. It also includes individuals and organisations working in the defence sector, such as high-ranking and military officials, as well as companies supporting the Russian armed forces. The EU also continues to target those who spread disinformation about the war.
EU restrictive measure target key decision makers, oligarchs, senior military officials and propagandists, responsible for undermining Ukraine's territorial integrity.
- Extension of restrictions to the oblasts of Kherson and Zaporizhzhia: The geographical scope of the restrictive measures in response to the recognition of the non-government controlled areas of the Donetsk and Luhansk oblasts of Ukraine and the ordering of Russian armed forces into those areas has been extended to cover all the non-government controlled areas of Ukraine in the oblasts of Donetsk, Luhansk, Zaporizhzhia and Kherson.
- New export restrictions: Additional export restrictions have been introduced that aim to reduce Russia's access to military, industrial and technological items, as well as its ability to develop its defence and security sector.
This includes a ban on the export of coal including coking coal (which is used in Russian industrial plants), specific electronic components (found in Russian weapons), technical items used in the aviation sector, as well as certain chemicals.
A prohibition on exporting small arms and other goods under the anti-torture Regulation has been added.
- New import restrictions: Almost €7 billion worth of additional import restrictions have been agreed.
This includes, for example, a ban on the import of Russian finished and semi-finished steel products (subject to a transition period for some semi-finished), machinery and appliances, plastics, vehicles, textiles, footwear, leather, ceramics, certain chemical products, and non-gold jewellery.
- Implementing the G7 oil price cap: This package marks the beginning of the implementation within the EU of the G7 agreement on Russian oil exports. While the EU's ban on importing Russian seaborne crude oil remains fully in place, the price cap, once implemented, would allow European operators to carry out and support the transport of Russian oil to non-EU countries, provided its price remains under a pre-set “cap”. This will help to further reduce Russia's revenues, while keeping global energy markets stable through continued supplies. It will therefore also help address inflation and keep energy costs stable at a time when high costs – particularly elevated fuel prices – are a great concern to all Europeans.
This measure, after being closely coordinated with G7 partners, took effect following a further decision by the Council: It took effect from 5 December 2022 for crude and 5 February 2023 for refined petroleum products.
- Restrictions on State-owned enterprises: This package bans EU nationals from holding posts in the governing bodies of certain state-owned enterprises.
It also bans all transactions with the Russian Maritime Register, adding it to the list of state-owned enterprises that are subject to a transaction ban.
- Financial, IT consultancy and other business services: The existing prohibitions on crypto assets have been tightened by banning all crypto-asset wallets, accounts, or custody services, irrespective of the amount of the wallet (previously up to €10,000 was allowed).
The package widens the scope of services that can no longer be provided to the government of Russia or legal persons established in Russia: these now include IT consultancy, legal advisory, architecture and engineering services. These are significant as they will potentially weaken Russia's industrial capacity because it is highly dependent on importing these services.
- Deterring sanctions circumvention: The EU has introduced a new listing criterion, which will allow it to sanction individuals who facilitate the infringements of the prohibition against circumvention of sanctions.
For more information
The Council of the European Union adopted the following additional measures
- Gold import ban: The import of all gold originating from Russia and exported from Russia into the EU or to any non-EU country is prohibited. An exemption applies for gold jewellery of travellers for their personal use
- Reporting requirements strengthened: Sanctioned people are obliged to declare their assets, in order to facilitate the freezing of their assets in the EU
- Targeted export bans: Export controls on dual use and advanced technology is reinforced by extending the list of items that could contribute to Russia’s military and technological improvements or the development of the country's militaryu and security sector
- Port access ban: Russian flagged vessels are banned from accessing locks to prevent the circumvention of sanctions
- Financial sanctions: The ban on accepting deposits is extended to deposits from legal persons, organisations or bodies established in non-EU countries and majority-owned by Russian nationals or natural persons residing in Russia. Additionally, the acceptance of deposits for non-prohibited cross-border trade will be subject to a prior authorisation by national competent authorities
- Food and energy security: Transactions for agricultural products and the transport of oil to non-EU countries with certain state-owned organisations are exempted
- Medical and pharmaceutical exemptions: Exemptions are added for certain export prohibitions for medical and pharmaceutical purposes
- Clarifications: introduction of a number of clarifications to existing measures, for instance in the field of public procurement, aviation and justice
- Assets freezes: Adding of a further 54 individuals and 10 organisations on the list
For more information
The Council of the European Union adopted the following additional measures:
- Oil import restrictions
- Crude and refined oil embargo: These sanctions will come into force with immediate effect, and will phase out Russian oil imports in an orderly fashion. For seaborne crude oil, spot market transactions and execution of existing contracts will be permitted for six months after entry into force, while for petroleum products, these will be permitted for eight months after entry into force. Member States who have a particular pipeline dependency on Russia can benefit from a temporary exemption and continue to receive crude oil delivered by pipeline, until the Council decides otherwise. However, Member States benefiting from this exemption will not be able to resell such crude oil and petroleum products to other Member States or non-EU countries
- Due to its specific geographical exposure, a special temporary derogation until the end of 2024 has been agreed for Bulgaria which will be able to continue to import crude oil and petroleum products via maritime transport. In addition, Croatia will be able to authorise until the end of 2023 the import of Russian vacuum gas oil which is needed for the functioning of its refinery
- Crude and refined oil embargo: These sanctions will come into force with immediate effect, and will phase out Russian oil imports in an orderly fashion. For seaborne crude oil, spot market transactions and execution of existing contracts will be permitted for six months after entry into force, while for petroleum products, these will be permitted for eight months after entry into force. Member States who have a particular pipeline dependency on Russia can benefit from a temporary exemption and continue to receive crude oil delivered by pipeline, until the Council decides otherwise. However, Member States benefiting from this exemption will not be able to resell such crude oil and petroleum products to other Member States or non-EU countries
- Oil transport services
- After a wind down period of 6 months, EU operators will be prohibited from insuring and financing the transport, in particular through maritime routes, of oil to non-EU countries
- This will make it particularly difficult for Russia to continue exporting its crude oil and petroleum products to the rest of the world since EU operators are important providers of such services
- After a wind down period of 6 months, EU operators will be prohibited from insuring and financing the transport, in particular through maritime routes, of oil to non-EU countries
- Financial and business services measures
- An additional three Russian banks, Russia's largest bank Sberbank, Credit Bank of Moscow, and Russian Agricultural Bank – and the Belarusian Bank for Development and Reconstruction – have been removed from SWIFT. These banks are critical for the Russian financial system and Putin's ability to further wage war. It will solidify the isolation of the Russian financial sector from the global system
- The measures on trusts have been refined and appropriate exceptions have been laid down in a revised version of the provision (e.g. for humanitarian purposes or civil society)
- The provision of certain business-relevant services – directly or indirectly – such as accounting, auditing, statutory audit, bookkeeping and tax consulting services, business and management consulting, and public relations services to the Russian government, as well as to legal persons, organisations or bodies established in Russia are now prohibited
- An additional three Russian banks, Russia's largest bank Sberbank, Credit Bank of Moscow, and Russian Agricultural Bank – and the Belarusian Bank for Development and Reconstruction – have been removed from SWIFT. These banks are critical for the Russian financial system and Putin's ability to further wage war. It will solidify the isolation of the Russian financial sector from the global system
- Broadcasting suspension
- The broadcasting activities of another three Russian State outlets – Rossiya RTR/RTR Planeta, Rossiya 24/Russia 24, and TV Centre International – have been suspended. They are among the most important pro-Kremlin disinformation outlets targeting audiences in Ukraine and the EU, and disseminating propaganda in support of Russia's aggression against Ukraine
- Several regulators in EU Member States have already taken action against those Russian state-controlled broadcasters and channels. They will now be barred from distributing their content across the EU, in whatever shape or form, be it on cable, via satellite, on the internet or via smartphone apps
- The advertising of products or services on sanctioned outlets has also been prohibited
- The broadcasting activities of another three Russian State outlets – Rossiya RTR/RTR Planeta, Rossiya 24/Russia 24, and TV Centre International – have been suspended. They are among the most important pro-Kremlin disinformation outlets targeting audiences in Ukraine and the EU, and disseminating propaganda in support of Russia's aggression against Ukraine
- Export restrictions
- The list of advanced technology items banned from export to Russia has been expanded to include additional chemicals that could be used in the process of manufacturing chemical weapons. These are controlled since 2013 for other destinations such as Syria. Moreover, the package further expands the list of natural persons, legal persons or organisations associated with Russia's military-industrial complex. These natural persons, legal persons or organisations are involved in various sectors, such as electronics, communications, weapons, shipyards, engineering and scientific research. This update brings the EU into alignment with United States measures, while other partners are expected to align in the near future
- The package adds the United Kingdom and the Republic of Korea to the Annex of partner countries that have adopted substantially equivalent export restrictions
- The list of Belarusian organisations subject to restrictions has been significantly widened (from 1 to 25). This is related to authorisations for the sale, supply, transfer or export of dual-use goods and technology, as well as goods and technology that might contribute to Belarus's military and technological enhancement, or to the development of its defence and security sector
- The list of advanced technology items banned from export to Russia has been expanded to include additional chemicals that could be used in the process of manufacturing chemical weapons. These are controlled since 2013 for other destinations such as Syria. Moreover, the package further expands the list of natural persons, legal persons or organisations associated with Russia's military-industrial complex. These natural persons, legal persons or organisations are involved in various sectors, such as electronics, communications, weapons, shipyards, engineering and scientific research. This update brings the EU into alignment with United States measures, while other partners are expected to align in the near future
For more information
The Council of the European Union adopted the following restrictive measures:
- Coal ban: An import ban on all forms of Russian coal
- Financial measures: A full transaction ban and asset freeze on four additional Russian banks. A prohibition on providing high-value crypto-asset services to Russia. A prohibition on providing trust services to wealthy Russians, making it more difficult for them to store their wealth in the EU
- Transport: A full ban on Russian and Belarusian freight road operators working in the EU. Certain exemptions cover essentials, such as mail, agricultural and food products, humanitarian aid as well as energy. An entry ban on Russian-flagged vessels to EU ports. Exemptions apply for medical, food, energy, and humanitarian purposes, amongst others
- Targeted export bans: Further targeted export bans that include, in particular, quantum computing, advanced semiconductors, sensitive machinery, transportation and chemicals
- Extending import bans: Additional import bans including cement, rubber products, wood, spirits (including vodka), liquor, high-end seafood (including caviar), and an anti-circumvention measure against potash imports from Belarus
- Excluding Russia from public contracts and European money: Full prohibition on the participation of Russian nationals and organisations in procurement contracts in the EU. Restriction on financial and non-financial support to Russian publicly owned or controlled organisations under EU, Euratom and Member State programmes
- Legal clarifications: Extension of the prohibitions on the export of banknotes and on the sale of transferrable securities to Russian nationals or organisations to all official EU currencies
- Assets freezes: Addition of a further 217 individuals and 18 organisations on the list
Related documents
- Question and answers on the fifth package
- Council Regulation (EU) 2022/576 of 8 April 2022 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine
- Council Regulation (EU) 2022/580 of 8 April 2022 amending Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine
- Council Regulation (EU) 2022/577 of 8 April 2022 amending Regulation (EC) No 765/2006 concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine
The Council adopted the following restrictive measures:
- A full prohibition on transactions with certain Russian State-owned enterprises, with the exception of State-owned banks, railways and the maritime shipping register
- Prohibit EU agencies from providing financial rating services to Russian companies
- A ban on imports of iron and steel products currently under EU safeguard measures as well as new investments in the Russian energy sector, with the exception of nuclear energy and the transport of energy products
- Prohibit the export of luxury goods
- Add 15 individuals and 9 organisations to the list of sanctioned people and organisations, to include more oligarchs and business elites linked to the Kremlin, as well as companies active in military and defence sectors, and disinformation. With these additions, the list comprises a total of 877 individuals and 62 organisations.
Related documents
The Council adopted the following restrictive measures:
- Exclude three Belarusian banks from the SWIFT system
- Prohibit transactions with the Central Bank of Belarus related to the management of reserves or assets, and the provision of public financing for trade with and investment in Belarus
- Clarify the notion of “transferable securities” so as to clearly include crypto-assets, and thus ensure the proper implementation of the sectoral restrictions in place
- Prohibit the listing and provision of services in relation to shares of Belarus state-owned organisations on EU trading venues as of 12 April 2022
- Significantly limit the financial inflows from Belarus to the EU, by prohibiting the acceptance of deposits exceeding €100.000 from Belarusian nationals or residents, the holding of accounts of Belarusian clients by the EU central securities depositories, as well as the selling of euro-denominated securities to Belarusian clients
- Prohibit the provision of euro denominated banknotes to Belarus
- Further restrictive measures with regard to the export of maritime navigation goods and radio communication technology to Russia
- Add 160 individuals to the list of sanctioned people and organisations. With these additions, the list comprises a total of 862 individuals and 53 organisations
Related documents
- Commission press release of 9 March 2022
- Council press release on the extended sanctions adopted on 9 March 2022
- Council press release on the extended financial measures adopted on 9 March 2022
- Sanctions adopted on 9 March 2022 published in the Official Journal
- Extended financial measures adopted on 9 March 2022 published in the Official Journal
The Council adopted the following restrictive measures:
- Exclude key Russian banks from the SWIFT system, the world's dominant financial messaging system. This measure will stop these banks from conducting their financial transactions worldwide in a fast and efficient manner. This decision was closely coordinated with the EU's international partners, such as the United States and the United Kingdom
- Prohibit investing in projects co-financed by the Russian Direct Investment Fund
- Prohibit the provision of euro-denominated banknotes to Russia
- Prohibit state-owned media Russia Today and Sputnik from broadcasting in the EU
- Restrictions on trade against Belarus and add 22 members of the Belarusian military personnel to the list of sanctioned people and organisations. With these additions, the list comprises a total of 702 individuals and 53 organisations
Related documents
- Commission press release of 2 March 2022 on SWIFT and further restrictive measures
- Council press release of 2 March 2022 on SWIFT and further restrictive measures
- Council press release of 2 March 2022 on Belarus
- Sanctions adopted on 2 March 2022 on SWIFT published in the Official Journal
- Sanctions adopted on 2 March 2022 on Belarus published in the Official Journal
The Council adopted the following restrictive measures:
- A ban on transactions with the Russian Central Bank, aiming at preventing the Russian Central Bank from accessing its large amounts of foreign reserves held in the EU
- A ban on the overflight of EU airspace and on access to EU airports by Russian carriers of all kinds
- Add 26 individuals and 1 organisation to the list of sanctioned people and organisations. With these additions, the list comprises a total of 680 individuals and 53 organisations
Related documents
- Council press release of 28 February 2022
- Sanctions adopted on 28 February 2022 on transactions with the Russian Central Bank and measures on airspace published in the Official Journal
- Sanctions adopted on 28 February 2022 on the list of sanctioned persons and organisations published in the Official Journal
Following up on the conclusions of the European Council on 24 February 2022, the Council adopted on 25 February the following package of individual and economic measures
- Financial sector sanctions that will cut Russia's access to the most important capital markets, targeting 70% of the Russian banking market, but also key state-owned companies, including the field of defence
- Energy sector sanctions that will prohibit the sale, supply, transfer or export to Russia of specific goods and technologies in oil refining, and will introduce restrictions on the provision of related services
- Transport sector sanctions that will ban the sale of all aircraft, spare parts and equipment to Russian airlines. This will degrade the key sector of Russia's economy and the country's connectivity
- Technology sector sanctions imposing further restrictions on exports of dual-use goods and technology, as well as restrictions on exports of certain goods and technology which might contribute to Russia’s technological enhancement of its defence and security sector
- Visa policy sanctions that mean diplomats and related groups, and business people will no longer have privileged access to the EU. With these additions, the list of sanctioned persons and organisations comprises a total of 654 individuals and 52 organisations
Related documents
In response to Russia recognising the non-government controlled areas of the Donetsk and Luhansk oblasts of Ukraine and its decision to send troops into the region, the Council adopted a package of sanctions on 23 February 2022. These sanctions target
- the ability of the Russian state and government to access the EU’s capital and financial markets and services, to limit the financing of escalatory and aggressive policies
- economic relations between the two non-government controlled regions and the EU, to ensure that those responsible clearly feel the economic consequences of their illegal and aggressive actions
- individuals and organisations who played a role in undermining or threatening the territorial integrity and independence of Ukraine. With these additions, the list comprises a total of 555 individuals and 52 organisations
Related documents
Economic sanctions on Russia
The economic (or sectoral) sanctions target exchanges with Russia in specific economic sectors. The sanctions regime laying down these measures consists of Council Decision 2014/512/CFSP and Council Regulation (EU) No 833/2014.
As of 19 December 2023, the economic sanctions regime includes the following measures
Financial measures
- Blocking of the Russian Central Bank’s reserves and assets, as well as a prohibition on the financing of the Russian government and Central Bank
- Prohibitions on a range of financial interactions, financial rating services and transactions with Russia, as well as prohibitions on the provision of banknotes and sale of securities
- Decoupling of certain Russian banks from the SWIFT messaging system
- Prohibition on public financing or financial assistance for trade with, or investment in Russia
- Prohibition on investment and contribution to projects co-financed by the Russian Direct Investment Fund
- Full exclusion of Russia from public contracts and European money
- Prohibition on providing crypto services and trust services
- Prohibition on accepting deposits
Commerce-related measures
- Arms embargo
- Prohibition on exports of
- Dual-use goods and advanced technology items that can contribute to Russia’s defence and security capabilities (e.g. quantum computers and advanced semiconductors, electronic components and software)
- Goods contributing to the enhancement of Russian industrial capacities, including the energy industry
- Transportation equipment, goods used in aviation, space industry and maritime navigation
- Civilian firearms
- Prohibition on imports of
- Iron and steel, including of some goods processed in third countries using Russian inputs
- Cement, rubber products, wood, aluminium spirits, liquor, high-end seafood and other goods generating significant revenues for Russia
- Gold and diamonds
- Transit bans for certain prohibited goods via the Russian territory
- Prohibition to provide technical assistance or brokering services for prohibited goods, as well as to sell, license, transfer or refer intellectual property rights and trade secrets
- “Anti-circumvention tool” which allows for restrictions on the export of sanctioned goods to third countries with continued and particularly high risk of circumvention
- Obligation for operators to contractually prohibit the re-export of certain sanctioned goods
- Prohibition to provide certain services (business, legal advisory, IT consultancy etc.)
Transport
- Prohibition on certain operations in the aviation sector (airspace closure)
- Notification requirements for private flights between the EU and Russia
- Prohibition on Russian freight operators and on the use of Russian trailers and semi-trailers
- Prohibition to access EU ports and locks for Russian-flagged vessels and vessels which manipulate or turn-off navigation systems when transporting Russian oil
Energy
- Prohibition on new investments in the energy sector
- Prohibition on the export of goods for use in the oil industry
- Prohibition on the import of coal, peat and LPG (liquified petroleum gas) and seaborne crude oil
- Prohibition on providing oil transport services
- Implementation of the G7 oil price cap for Russian oil exports (see further details in the next section)
- Prohibition on Russian nationals and entities to book gas storage capacity in the Union
- Prohibition to import Russian oil via pipeline for some Member States
Media
- Prohibition on the broadcast in the EU of certain Russian state-owned media outlets
The G7 Oil Price Cap Coalition established an oil price cap mechanism on Russian seaborne crude oil and petroleum products. EU operators are only allowed to provide maritime transport and related services for Russian crude oil and petroleum products if these are sold at or below the relevant price caps. This mechanism has been specifically designed to further reduce Russia's revenues, while keeping global energy markets stable through continued supplies. It is applicable to Russian crude oil since 5 December 2022, and to Russian petroleum products since 5 February 2023.
Provisions relating to the Russian oil price cap are laid down in Council Decision 2014/512/CFSP and Council Regulation (EU) No 833/2014.
- Article 3n of Council Regulation (EU) No 833/2014 sets out the Russian oil price cap mechanism
- Articles 3eb and 3ec of Council Regulation (EU) No 833/2014 set out EU port access bans for vessels which are transporting Russian oil and have conducted ship–to-ship transfers or turned off their AIS navigation systems during the voyage to a Member State, giving reasons to suspect a breach of the price cap or the Russian oil import ban
- Article 3q of Council Regulation (EU) No 833/2014 sets out an obligation to notify the sale of tankers and seek an authorisation for such sale if to a Russian person or for use in Russia. This measure seeks to more closely monitor sales to help to tackle the ‘shadow fleet' used by Russia to circumvent the Russian oil price cap
- Article 3na of Council Regulation (EU) No 833/2014 sets out information sharing mechanism between Member States and the Commission to further identify vessels and entities engaging in deceptive practices while transporting Russian crude oil and petroleum products
EU guidance
- EU compliance alert on the G7+ Oil Price Cap
- Russian oil price cap FAQs
- Russian oil import ban FAQs
- Notification and authorisation of tanker sales FAQs
- Notification of tanker sales - template
Price Cap Coalition guidance and statements
The measures consist of travel bans and financial measures (asset freezes and a prohibition on making funds or economic resources available) that now target a total of 1 206 individuals and over 108 organisations responsible for undermining Ukraine’s territorial integrity, sovereignty and independence. This sanctions regime consists of Council Decision 2014/145/CFSP and Council Regulation (EU) No 269/2014.
Since 2014, restrictions on trade and investment have been imposed regarding to Crimea and Sevastopol. This sanctions regime consists of Council Decision 2014/386/CFSP and Council Regulation (EU) No 692/2014.
In 2022, restrictions on trade and investment were also imposed regarding to the non-government controlled areas of Donetsk, Kherson, Luhansk and Zaporizhzhia oblasts of Ukraine. This sanctions regime consists of Council Decisions (CFSP) 2022/266 and Council Regulation (EU) 2022/263. The measures therein are very similar to those concerning Crimea and Sevastopol.
Since 2020, a wide range of restrictive measures have been imposed regarding Belarus, including economic sanctions, individual restrictive measures and restrictions on trade. All these measures form part of a single sanctions regime consisting of Council Decision 2012/642/CFSP and Council Regulation (EC) No 765/2006.
In July 2023, the Council prohibited the export, transfer, sale or supply of components used in the manufacturing of UAVs (unmanned aerial vehicles, “drones”) to Iran or for use in Iran. It also imposed travel bans and financial measures (asset freezes and a prohibition on making funds or economic resources available) on persons and entities responsible for, or involved in, the Iranian state-sponsored programme for the development and production of UAVs. In December 2023, six persons and five entities were designated. This sanctions regime consists of Council Decision (CFSP) 2023/1532 and Council Regulation (EU) 2023/1529.
Guidance documents and frequently asked questions
Member States are responsible for implementing sanctions. The Commission oversees the implementation by Member States and is working closely with them in order to support them on implementation, provide information to stakeholders, and engage in a dialogue to collect feedback on how sanctions are implemented.
The Commission has published guidance and extensive FAQs (over 500) covering a broad range of topics and continues to update them, in order to assist stakeholders on how to apply the sanctions packages.
Request for feedback
The Directorate-General for Financial Stability, Financial Services and Capital Markets Union (DG FISMA) invited stakeholders to give feedback on Article 12g of Council Regulation (EU) No 833/2014 ('no re-export to Russia' clause), which was laid down via the 12th package of EU sanctions imposed on Russia, and later amended in the 14th package. Article 12g requires the use of a ‘no re-export to Russia’ clause in certain contracts concerning sensitive goods. DG FISMA is seeking feedback on the application of this measure in the context of the EU’s efforts to deter circumvention.
EU operators, associations and other relevant stakeholders were invited to share their experiences and views by 1 December 2024 23:59 (CET).
Contacts
EU economic operators: ec-russia-sanctionsec [dot] europa [dot] eu (ec-russia-sanctions[at]ec[dot]europa[dot]eu)
The primary responsibility for the implementation of EU sanctions rests with the Member States. Therefore, when in need of guidance on specific cases, EU operators should foremost reach out to their national competent authority. However, this contact point allows for particularly complex matters to be raised with the European Commission.
EU public: Europe Direct Contact Point
Citizens should address their queries to the Europe Direct Contact Point.
Foreign authorities and operators: ec-sanctions-internationalec [dot] europa [dot] eu (ec-sanctions-international[at]ec[dot]europa[dot]eu)
The aim of the contact point is to encourage foreign (non-EU) authorities and operators to reach out directly to the Commission when facing difficulties in interpreting EU sanctions. It is also meant to help ensure that the flow of agrifood products and fertilisers to their countries continues unimpeded.