In response to Russia’s war of aggression against Ukraine in 2022, the European Union has imposed massive and unprecedented sanctions against Russia. These add to the existing measures that have already been imposed on Russia since 2014 due to the annexation of Crimea and the non-implementation of the Minsk agreements. The sanctions include targeted restrictive measures aimed at individuals responsible for supporting or financing actions aimed against the integrity of Ukraine, such as Russian President Vladimir Putin; the Russian Minister of Foreign Affairs; the former President of Ukraine as well as high-ranking officials, military personnel and prominent businesspeople and oligarchs. Among the entities targeted are banks and financial institutions, companies in the military, aviation, shipbuilding and machine building sectors, political parties and media organisations. These sanctions include the freezing of assets in EU banks, travel bans, and visa measures. To that end, the EU has also imposed import and export restrictions on Russia. Goods that cannot be exported to Russia include:

• Highly modern technology
• Army materials, machinery and transportation equipment
• Equipment needed for oil refining
• Chemicals
• Lithium batteries
• thermostats
• goods and technology needed for aviation and space industry, maritime navigation and radio communication
• So-called “dual-use goods”, that can be used for both civil and military purposes, such as drones and encryption devices
• Luxury products, like cars, watches and jewellery
• civilian firearms and their parts

Please note that this list is not exhaustive and is subject to change.

Russian Exporting Bans

Russia on the other hand is prohibited from exporting resources, such as crude oil and refined petroleum products; coal; steel; iron; gold and diamonds and wood, as well as other goods including seafood, liquor, jewellery, cigarettes and cosmetics to the EU.

Since the beginning of Russia’s war of aggression against Ukraine, the European Union and Germany have been working on improving the implementation and enforcement of sanctions within member states. In 2022, Germany has adopted a ‘Second Act for more effective sanctions enforcement’ (Sanctions Enforcement Act II), which includes the creation of a Central Office for Sanctions Enforcement, the implementation of a partly public register for property potentially subject to sanctions, a contact point for whistleblowers and a ban of cash payments in property transactions to prevent money laundering.

Furthermore, the EU has adopted the 11th EU sanctions package against Russia in June 2023. This aims to increase the traceability of exports and to prevent the circumvention of sanctions via third countries more effectively. It also includes a general obligation for anyone possessing information about potential violations of sanctions to report those to competent authorities – otherwise an administrative penalty may be imposed. The European Commission has also appointed a special EU envoy in 2023, who is responsible for enforcing EU sanctions internationally with partner countries and third states, especially regarding Russia.

At Schlun & Elseven, we are aware of the multifaceted and wide-ranging consequences of sanctions and embargos. Our lawyers offer comprehensive knowledge and long-standing experience in international and European law matters and have a deep understanding of international sanctions and their enforcement mechanisms. Whether you are seeking counsel to navigate complex compliance requirements or are faced with allegations of sanctions violations, don’t hesitate to contact us through our encrypted contact form for more information.