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European Union Sanctions imposed onto Russia in connection with the War in Ukraine

The war in Ukraine has prompted the European Union to take several measures to put pressures upon Russia to stop such war.

In particular, on 23 February 2022, the European Union adopted a first range of measures:

  • Council Regulation (EU) 2022/259 has introduced a derogation to allow for the release of funds for the termination of contracts by 24 August 2022.

  • Council Implementing Regulation (EU) 2022/260 has identified 22 people and four entities to be inserted in the asset freeze list.

  • Council Implementing Regulation (EU) 2022/261 has inserted the 336 members of the Russian State Duma to the asset freeze list.

  • Council Regulation (EU) 2022/262 prohibits dealing with transferable securities and money-market instruments issued after 9 March 2022 by the Russian government or the Central Bank of Russia, or making loans or credit available to such entities.

  • Council Regulation (EU) 2022/263 relates to the areas of Donetsk and Luhansk actually not controlled by the Government of Ukraine: it has imposed an import ban on all goods from the regions into the EU and a prohibition on financing; restricts certain investments in the regions; restricts trade and investment; prohibits the supply of tourism services; bans exports on specified goods and technologies; and prohibits certain services in the transport, telecommunications, energy or oil, gas and mineral sectors.

Further measures were taken by the European Union after the beginning of the actual war on 24 February 2022. The following measures were consequently imposed on 25 February 2022:

  • Council Regulation (EU) 2022/328, prohibiting the listing of Russian state-owned entities in the EU and limiting the value of deposits made by Russian nationals in the EU; introducing an export ban on goods and technologies in the oil refining, aviation and space sectors; prohibiting insurance, financial and technical services relating to goods and services in the aviation and space sectors; and imposing a restriction on exports of dual-use items and technology.

  • Council Regulation (EU) 2022/330, broadening the asset freeze listing criteria.

  • Council Regulation Implementing (EU) 2022/332, designating for banning purposes 98 individuals and entities, including the Russian President and Minister of Foreign Affairs, members of the National Security Council and the remaining members of the Russian State Duma.

Finally, on 26 February 2022, the Governments of the United Kingdom, France, Germany, Italy, Canada and the United States committed to the introduction of some additional financial measures inclusive of: (a) removing certain Russian banks from the SWIFT messaging system, (b) imposing restrictive measures on the Russian Central Bank to prevent it from undermining sanctions, (c) placing restrictions on wealthy Russians gaining access to the financial systems of the allies, and (d) launching a transatlantic task force to ensure that all such sanctions are effectively implemented and enforced.

On top of all the foregoing, the European Governments are also assisting into the implementation of U.S. export-control regulations, which are binding not only on Russian entities, but also on intermediary manufacturers of products sold to Russian entities, when such products include technology (inclusive of software) originating from U.S.A.. This will affect many European products suppliers in their business activities carried out with Russian buyers.

Prof. Avv. Salvatore Vitale

The content of this article does not constitute legal advice, but has an informative function. For tailor made legal advice, contact the firm by e-mail to: or by phone +39 06 916505710. © Dong & Partners International Law Firm, All rights reserved.

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