EU Adopts 13th Package Of Sanctions Against Russia – Export Controls & Trade & Investment Sanctions

On February 23, 2024, the EU adopted the 13th package of
sanctions against Russia with the occasion of the 2nd year mark of
the full-scale invasion.¹

This package focuses on further limiting Russia’s access to
military technologies, such as for drones, and on listing
additional companies and individuals involved in Russia’s war
effort. With this new package the number of individual listings has
reached over 2000.² The key elements of the 13th package
are the following:

Designations

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. The designations specifically
target:

1. Russia’s military and defense sector (including
   manufacturers of missiles; drones, anti-aircraft system, military
   vehicles, high-tech components for weapons and other military
   equipment);




2. Third country public administrations, corporations and
   individuals partnering with Russia for the provision of military
   equipment (the designations target the Defence Minister of the
   DPRK, as well as several Belarusian companies and
   individuals);




3. Entities involved in circumvention;




4. Individuals and entities involved in violation of children
   rights;




5. Authorities from occupied territory: six judges and 10
   officials in the occupied territories of Ukraine.

Those designated are subject to an asset freeze and EU citizens
and companies are forbidden from making funds available to them.
Natural persons are additionally subject to a travel ban, which
prevents them from entering or transiting through EU
territories.

Import-export controls and restrictions

The EU added 27 new entities to the list³ of those
directly supporting Russia’s military and industrial complex in
its war of aggression against Ukraine. They are now subject to
tighter export restrictions concerning dual use goods and
technologies, as well as goods and technology which might
contribute to the technological enhancement of Russia’s defence
and security sector.

Some of these entities are located in third countries (India,
Sri Lanka, China, Serbia, Kazakhstan, Thailand, and Turkey) and
have been involved in the circumvention of trade restrictions,
others are Russian entities involved in the development, production
and supply of electronic components for Russia’s military and
industrial complex.⁴

The new sanctions package also expands the list of restricted
items that could contribute to the technological enhancement of
Russia’s defence and security sector⁵ by adding
components for the development and production of unmanned aerial
vehicles (UAV) such as electric transformers, static converters and
inductors as well as aluminum capacitors.

Lastly, the EU introduced further restrictions on exports of
goods which contribute in particular to the enhancement of Russian
industrial capabilities, such as electrical
transformers.⁶

Iron & steel

The EU has added the United Kingdom to a list of partner
countries which apply a set of restrictive measures on imports of
iron and steel from Russia.⁷

Curtis is closely monitoring any legislative development. Curtis
is committed to provide the best advice to its clients on how to
navigate the complex regulatory environment.

Footnotes

1. See: Council Implementing Regulation
(EU) 2024/753 of 23 February 2024 implementing Regulation (EU) No
269/2014 concerning restrictive measures in respect of actions
undermining or threatening the territorial integrity, sovereignty
and independence of Ukraine, OJ L, 2024/753, 23.02.2024, available
at:
https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=OJ:L_202400753.
Also: Council Regulation (EU) 2024/745 of 23 February 2024 amending
Regulation (EU) No 833/2014 concerning restrictive measures in view
of Russia’s actions destabilising the situation in Ukraine, OJ
L, 2024/745, 23.02.2024, available at:
https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=OJ:L_202400745

2. EU Commission press release, EU adopts
13th package of sanctions against Russia after two years of its war
of aggression against Ukraine IP 24-963 (Feb. 23, 2024), available
at:
https://ec.europa.eu/commission/presscorner/detail/en/ip_24_963

3. Annex IV referred to in Articles 2(7),
2a(7) and 2b(1) of Council Regulation (EU) No. 833/2014.

4. EU Council of the European Union,
Russia: two years after the full-scale invasion and war of
aggression against Ukraine, EU adopts 13th package of individual
and economic sanctions(Feb. 23, 2024), available at:
https://www.consilium.europa.eu/en/press/press-releases/2024/02/23/russia-two-years-after-the-full-scale-invasion-and-war-of-aggression-against-ukraine-eu-adopts-13th-package-of-individual-and-economic-sanctions/

5. Annex VII containing the List of goods
and technology referred to in Articles 2a(1) and 2b(1) of Council
Regulation (EU) No. 833/2014.

6. Annex XXIII containing the List of
goods and technology as referred to in Article 3k of Council
Regulation (EU) No. 833/2014.

7. Annex XXXVI List of partner countries
for importation of iron and steel as referred to in Articles 3g(1)
of Council Regulation (EU) No. 833/2014.

Originally published 28 Feb. 2024

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