Additional European sanctions in connection with the crisis in Ukraine

March 03, 2022
Frédéric Puel,
Ioulia Tsoukanova

We must be honest and frank with one another. Those sanctions will also come at a cost to ourselves.” (Charles Michel, President of the European Council, 1 March 2022)

On February 25, the EU Council adopted (as announced on February 23) a new set of sanctions:

  • Prohibition of export and provision of technical and financial assistance or aid for "dual-use" goods and technologies or those that may contribute to military and technological build-up in Russia or for use in Russia. This prohibition does not apply if they are used for humanitarian, medical, or purely personal purposes. There are other exceptions;
  • A ban on the provision of financing or public financial assistance for trade with or investment in Russia. This prohibition shall not apply to binding commitments (i) entered into before 26 February 2022, (ii) up to a total amount of EUR 10 000 000 per project to SMEs established in the Union or (iii) to the provision of public financing or financial assistance for trade in foodstuffs and for agricultural, medical or humanitarian purposes ;
  • A ban on the supply or export of goods and technology suitable for use in the petroleum refining, aviation or space industries, or related technical or financial assistance. The text provides for the same exceptions as the one mentioned above. This prohibition does not apply to contracts concluded before February 26, 2022;
  • Prohibition, under certain conditions, of transactions in securities and money market instruments issued after April 12, 2022 by Russian banks;
  • Restrictions on visas and entry into the territory of the EU of (i) persons of official delegations of the Russian Federation (ii) businessmen and representatives of business organizations, (iii) members of national and regional governments and parliaments of the Russian Federation (iv) citizens of the Russian Federation holding a valid diplomatic passport issued by the Russian Federation

On 27 February 2022, in her statement, the President of the European Commission, Ursula Von der Leyen, announced further measures to:

  • Prohibit any aircraft registered in Russia and any aircraft not registered in Russia which is owned, chartered or otherwise controlled by a Russian natural or legal person, entity or body from landing in, taking off from or flying over the territory of the Union.
  • Ban the broadcasting in the EU of Russia Today and Sputnik and their subsidiaries;
  • Exclude major Russian banks from the SWIFT system
  • Prohibit transactions related to the management of reserves and assets of the Central Bank of Russia and any legal person, entity or body acting on its behalf
  • To prohibit the export of goods and technologies from the most important sectors of Belarus.

On 28 February 2022, the Council of the EU approved:

  • the ban on transactions with the Russian Central Bank;
  • the ban on overflight of EU airspace and access to EU airports for all types of Russian carriers;
  • new sanctions against individuals and entities.

To date, 680 individuals and 53 entities are subject to an asset freeze and entry ban in the EU.

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