11th Package of Sanctions imposed on Russia by EU
Circular Ref: A(23)109
Issue Date: 26 Jun 2023
The EU Council adopted the 11th package of EU sanctions against Russia on June 23rd.
The main objective of this package is to tighten loopholes and tackle circumvention, aiming to restrict trade with nations involved in bypassing Russia trade restrictions. It includes measures to combat sanctions circumvention, such as banning "shadow" entities intentionally bypassing EU sanctions. It is expected that this package will sanction further individuals/entities as well as seek to ensure that sanctions are implemented effectively and are harder to circumvent. 87 new entities have been added to the list of those directly supporting Russia. 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.
In particular, the package includes the following measures:
* A ban on the import of Russian seaborne crude oil and petroleum products into the EU. This ban will be phased in over a period of six months for crude oil and eight months for petroleum products.
* A ban on the provision of insurance and reinsurance services for the transport of Russian oil. This ban will make it more difficult for Russia to export its oil, as it will be more difficult for Russian oil tankers to obtain insurance.
* A ban on the provision of technical assistance and brokering services related to the oil and gas sector in Russia. This ban will make it more difficult for Russia to maintain and upgrade its oil and gas infrastructure.
* A ban on the import of gold from Russia.
* A ban on the export of luxury goods to Russia.
In addition to these measures, the package also includes a number of measures to prevent sanctions circumvention. These measures include:
* A ban on the use of "shadow" entities to circumvent sanctions.
* A ban on the transfer of ownership of sanctioned assets to “shadow" entities.
* A requirement for companies to report any suspicious transactions that could be related to sanctions circumvention.
The EU Council has also decided to prohibit access to EU ports and locks to any vessels that engage in ship-to-ship transfers, if the competent authorities have reasonable cause to suspect that the vessel is either in breach of the ban on importing seaborne Russian crude oil and petroleum products into the EU, or is transporting Russian crude oil or petroleum products purchased above the price cap agreed by the Price Cap Coalition.
The same prohibition will apply to vessels when competent authorities have solid reasons to suspect that they illegally interfere, switch off or otherwise disable their navigation system when transporting Russian crude oil and petroleum products in breach of international agreements, rules and standards.
We request you to familiarize yourselves with these new sanctions and to take steps as deemed necessary. If you have any questions, please do not hesitate to contact us.