EU adopts 9th package of Russian economic and individual sanctions

The EU has adopted its 9^th Sanctions Package further expanding the scope of the existing sanctions and restrictive measures, as well as adding to the list of sanctioned individuals and entities.

The agreed package includes a series of measures intended to damage the Russian economy and Putin’s ability to continue its aggression, including restrictions impacting the export, broadcasting, banking and mining sectors.

Export controls and restrictions

The sanctions package also contains various components that extend or enhance the various, already existing, export control and import restrictions.

—  the list of restricted items which might contribute to Russia’s military and technological enhancement or the development of its defence and security sector (“Annex VII items”) was extended through the addition of drone engines, further chemical and biological equipment, riot control agents and electronic components.

—  the list of entities (“Annex IV entities”) against whom tighter export restrictions regarding dual-use goods and technology as well as Annex VII items are imposed was extended.

—  the export ban covering goods and technology suited for use in aviation and the space industry (“Annex XI items”) was extended to include aircraft engines and their parts. For these goods, a grandfathering clause allows for the temporary execution of contracts concluded before the entry into force of the new measures.

• New ground for authorization 1: the provision of technical assistance relating to Annex XI items can be authorized by national competent authorities if it is necessary for avoiding collision between satellites, or their unintended re-entry into the atmosphere.
• New ground for authorization 2: the sale, supply, transfer, export of a limited number of Annex XI items (and technical assistance relating to them) can be authorized by national competent authorities if necessary for medical or pharmaceutical purposes, or for humanitarian purposes, such as delivering or facilitating the delivery of assistance, including medical supplies, food, or the transfer of humanitarian workers and related assistance or for evacuations.

—  the list of goods which could contribute to the enhancement of Russian industrial capacities (“Annex XXIII items”) was extended through the inclusion of items such as generators, toy drones, laptops, hard drives, IT components, night-vision and radio-navigation equipment, cameras and lenses. For these goods, a grandfathering clause allows for the temporary execution of contracts concluded before the entry into force of the new measures was adopted.

—  the grandfathering clause allowing an exemption to the export restriction on goods which generate significant revenues for Russia (“Article XXI items”) is extended by 6 months for methanol only.

—  New general ground for authorization: Competent authorities can authorize under conditions the sale, supply or transfer of goods and technologies listed in Annexes II, VII, X, XI, XVI, XVIII, XX and XXIII, or dual-use items until 30 September 2023, where such sale, supply or transfer is strictly necessary for the divestment from Russia or the wind-down of business activities in Russia.