Update EU-Sanktionen | 10. Maßnahmenpaket

The 10th sanctions package with amendments in Regulation 269/2014 (here and here) and Regulation 833/2014 (here) was published in the Official Journal (here) on Saturday. As per usual I have included changes in the attached master document and separate attachments. They can be summarized as follows:


  1. Designation (asset freeze) of additional 87 individuals and 34 entities, see the two attached lists. The entities include banks such as Alfa-Bank, Rosbank, and Tinkoff Bank, the National Wealth Fund of the Russian Federation, and the Russian National Reinsurance Company. They also include car manufacturers (e.g. Commercial Vehicles – GAZ Group) and other important manufacturers.


  1. New bans on:


  1. exports of critical technology and industrial goods, such as electronics, specialised vehicles, machine parts, spare parts for trucks and jet engines, as well as goods for the construction sector which can be directed to Russia’s military, such as antennas or cranes (see attached Annex XXIII; Article 3k Regulation 833/2014)
  2. an amended list of restricted items that could contribute to the technological enhancement of Russia’s defence and security sector  – they now include additional new electronic components including drones, missiles, helicopters, as well as specific rare earth materials, electronic integrated circuits, and thermal cameras (see attached Annex VII; Article 2a Regulation 833/2014);
  3. imports of asphalt and synthetic rubber (see attached XXI; Article 3i Regulation 833/2014);
  4. provision of gas storage capacity to Russians (see new Article 5 p Regulation 833/2014); and
  5. prohibit the transit through Russia of EU exported dual use goods and technology, in order to avoid circumvention.


  1. The EU has also:


  1. introduced the possibility to provide transitional services to a Russian subsidiary after the exit (deadline 31 December 2023; see new Article 12b (2a) Regulation 833/2014), thereby making an exit from the Russian market easier from an EU sanctions perspective
  2. restricted the possibility for Russian nationals to hold any position in the governing bodies of (EU) critical infrastructures and entities (see new Article 5o Regulation 833/2014)
  3. expanded the deadline for wind down measures with certain state owned entities to 31 December 2023 (see Article 5aa Regulation 833/2014)
  4. introduced new reporting obligations to ensure the effectiveness of the asset freeze prohibitions