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EU adopts 12th package of sanctions against Russia


The long-awaited 12th package of sanctions against Russia over its invasion of Ukraine was announced yesterday afternoon on the 18th of December. As expected, the package includes restrictions on additional goods of Russian origin, including diamonds, measures to strengthen the price cap on Russian oil and a significant amount of new designated individuals and entities.

High Representative of the European Union for Foreign Affairs and Security Policy Josep Borrell made the following statement on the adoption of the 12th package of sanctions: 

"With this 12th package, we are putting forward a robust set of new listings and economic measures which will further weaken Russia's war machine. Our message is clear […]: we remain steadfast in our commitment to Ukraine and will continue to support its freedom and sovereignty". 

The new sanctions enters into force on the day following the publication in the EU Journal, i.e. on 19 December 2023. The new designations enter into force on the date of publication, i.e. on 18 December 2018. 

The measures included in the 12th package are set out in Council Regulation (EU) 2023/2878 of 18 December 2023 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia's actions destabilising the situation in Ukraine. Amongst other things, the new measures include: 

  • As expected, the EU is imposing a ban on the import, purchase or transfer of diamonds originating in, exported from or transiting Russia, and Russian diamonds processed in a third country, included in the new article 3p of Council Regulation 833/2014. The ban on Russian diamonds processed in third countries will be phased in from 1 March 2024 and completed by 1 September 2024. 
  • As a measure to prevent circumvention of the export ban on sensitive goods and technology, the new package requires EU exporters to contractually prohibit re-exportation to Russia or for the use in Russia when selling, supplying, transferring or exporting such goods and technology to a third country, as set out in the new article 12g. There is a wind-down period until 20 December 2024 or the expiry date of a relevant contract, whichever is earlier. 
  • The new package also includes additional restrictions on import and export of several goods. Restricted items now include goods which could contribute to the technological enhancement of Russia's defence and security sector, such as chemicals, lithium batteries, thermostats, DC motors and servomotors for UAV's, machine tools and machinery parts. 
  • Certain processed metals and aluminium products are also added to the list of goods which generate significant revenues for Russia, such as pig iron and spiegeleisen, copper wires, aluminium wires, foil, tubes and pipes. The prohibition does not apply to the execution until 20 March 2024 of contracts concluded before 19 December 2023, cf. para 3ca of article 3i in Council Regulation 833/2014. The import of pig iron and spiegeleisen is permitted subject to specific import quotas, cf. para 3cd of article 3i. 
  • A new import ban has been introduced on liquefied propane (LPG). The ban has a 12 month transitional period, allowing for the execution until 20 December 2024 of contracts concluded before 19 December 2023. 
  • Exemptions from the import restrictions are introduced certain personal use items. This includes for example the entry into the Union of EU citizens living in Russia by cars, provided the cars are not for sale and driven strictly for personal use, after authorization by the relevant Member State, as set out in the new paras. 3aa, 3ab, 3ac and 3ad of article 3i in Council Regulation 833/2014. 
  • The 12th package also contains a ban on the transit through Russia of battlefield goods, in addition to the existing ban on dual use goods and technologies. For goods listed in Annex XXIIIA there is a wind-down period until 20 March 2024 and for goods listed in Annex XXIIIB there is a wind-down period until 20 June 2024. 
  • The service ban in article 5n of Council Regulation 833/2014 is expanded to also include a prohibition on the provision of software for the management of enterprises and software for industrial design and manufacture.
  • As of 18 January 2024, Russian nationals are banned from owning, controlling or holding any posts on the governing bodies of the legal persons, entities or bodies providing crypto-asset wallet, account or custody services to Russian persons and residents. Quarterly notification requirements are also introduced for the transfer of funds exceeding 100 000 EUR outside the EU by an entity established in the EU owned more than 40% by an entity established in Russia. 
  • The new package seeks to tackle enforcement gaps linked to the oil price cap and clamp down on circumvention. A strengthened information sharing mechanism is introduced to better identify vessels and entities participating in deceptive practices, such as STS transfers to conceal the origin of the cargo and AIS manipulation while carrying Russian crude oil and petroleum products. The information sharing mechanism is included in the new article 3na of Council Regulation 833/2014. 
  • Service providers with no access to the purchase price per barrel of Russian crude oil and petroleum products are required to collect itemised price information for ancillary costs as provided by operators further up the supply chain. 
  • The Council also decided to introduce notification rules for the sale of tankers to any third country in order to make more transparent their sale and export, in particular in the case of second-hand carriers that could be used to evade the import ban on Russian crude or petroleum products and the G7 Price Cap. Without prior authorization from the competent authorities, the sale of specified tankers is prohibited, cf. the new article 3q of Council Regulation 833/2014.
  • The wind-down period for the import of certain steel products have been extended until 1 October 2028. 
  • The temporary derogations for Croatia and Czechia from the import ban on certain Russian petroleum products are extended until 31 December 2024 and 5 December 2024, respectively. 
  • Lastly, the new package includes a significant amount of designations – of both individuals and entities. In total 61 individuals and 86 entities are designated in the new package. In addition, new designation criteria are introduced to target persons who benefit from the compulsory transfer of ownership or control over Russian subsidiaries of EU companies.

The new designations are set out in Council Implementing Regulation (EU) 2023/2875 of 18 December 2023 implementing Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine. Other changes to Council Regulation 269/2014, including designation criteria, are set out in Council Regulation (EU) 2023/2873.

The relevant press statements from the Council of the European Union and the European Commission can be found on their respective websites. The FAQs have not yet been updated. 

WR Sanctions Alerts provides you with updates on material developments in the country-specific sanctions programs implemented by the US, UN, UK, EU and Norway. We will not provide updates on mere extensions, without significant changes, of existing sanctions programs, nor on any listings or removals of persons/entities placed on implemented sanctions lists. Please note that WR Sanction Alerts are provided as general information and do not constitute legal advice.

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Tine Elisabeth Vigmostad
E-mail tvi@wr.no
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Marie Solberg Hatten
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