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February 27, 2023

LATEST UPDATES: EU reaction to Russian invasion of Ukraine (regularly updated)

Since the Russian invasion of Ukraine in February and March 2014 and the subsequent annexation of Crimea and Sevastopol to the Russian Federation (Russia) on 16 March 2014, declared illegal also by the UN General Assembly (UNGA/11493, 27 March 2014), the EU has adopted, under article 215 of the TFEU, a series of restrictive measures against persons and entities for their role in actions threatening the territorial integrity, sovereignty and independence of Ukraine[1].

Following Russia’s recognition of the Luhansk and Donetsk People’s Republics independence on 21 February 2022 and its further invasion of Ukraine on 24 February 2022, the EU adopted a new package of sanctions published in the Official Journal on February 23, 25 and 28[2].

The following are among the main measures implemented:

INDIVIDUAL SANCTIONS

  • Assets freezing of:
    • the Russian President, Vladimir Putin, and Minister of Foreign Affairs, Sergey Lavrov;
    • the members of the National Security Council of the Russian Federation who supported Russia’s immediate recognition of the two non-government-controlled areas of the Donetsk and Luhansk oblasts of Ukraine as independent entities;
    • the members of the Russian State Duma who ratified the government decision of the Treaty of Friendship, Cooperation and Mutual Assistance between the Russian Federation and the two entities;
    • the individuals who facilitated the Russian military aggression from Belarus;
    • Oligarchs, associates and advisors having particularly close ties to Russian President Vladimir Putin;
  • Prohibition from making funds available to the listed individuals and entities;
  • Travel ban applicable to the listed persons prevents these from entering or transiting through EU territory.

ECONOMIC SANCTIONS

  • Financial sanctions targeting 70% of the Russian banking market and key state-owned companies, such as:
    • restrictions on access by certain Russian entities to capital markets;
    • Prohibiting the acceptance of deposits exceeding certain values from Russian nationals or residents;
    • Prohibiting the holding of accounts of Russian clients by the Union central securities depositories;
    • Prohibiting the selling of euro-denominated securities to Russian clients;
    • Prohibiting the transactions of Russia’s central bank and freezing all its assets;
  • Energy sector
    • Prohibition of the sale, supply, transfer or export to Russia of specific goods and technologies in oil refining.
  • Transport sector
    • Export ban covering goods and technology in the aviation and space industry;
    • Prohibition on the provision of insurance and reinsurance and maintenance services related to those goods and technology;
    • Prohibition for Russian aircrafts or controlled by any Russian natural or legal person, entity or body from landing in, taking off from, or overflying, the territory (airspace) of the Union.
  • Technology sector
    • Restrictionson exports of dual-use goods and technology and on the provision of related services;
    • Restrictions on exports of certain goods and technology which might contribute to Russia’s technological enhancement of its defence and security sector, such as semiconductors or cutting-edge technologies.
  • Visa policy
    • Stop of benefit from visa facilitation provisions, for diplomats, other Russian officials, and business people (“this decision will not affect ordinary Russian citizens”).

Further sanctions are also being discussed, such as removing Russian banks from SWIFT (Society for Worldwide Interbank Financial Telecommunication) and some measures have already been taken to support the Union’s external policy towards Ukraine, such as the macro-financial assistance of a maximum amount of €1,2 billion available to Ukraine[3] and another €500 million military aid provided through the EU off-budget funding mechanism “European Peace Facility”[4].

EU SANCTIONS UPDATES:

In view of the gravity of the situation, and in response to Russia’s continued military aggression against Ukraine, the EU has introduced new measures as listed below.

2nd package of sanctions

Council Decision (CFSP) 2022/346 of 1 March 2022 amending Decision 2014/512/CFSP and Council Regulation (EU) 2022/345 of 1 March 2022 amending Regulation (EU) No 833/2014[5]:

  • The EU Member States competent authorities shall exchange information on dual-use goods and technology’s authorisations granted and denials issued with the other Member States and the Commission, as well as, where appropriate and on the basis of reciprocity, with partner countries;
  • Prohibition to invest, participate or otherwise contribute to projects co-financed by the Russian Direct Investment Fund;
  • Prohibition to provide SWIFT services to:
    • Bank Otkritie;
    • Novikombank;
    • Promsvyazbank;
    • Bank Rossiya;
    • Sovcombank;
    • VNESHECONOMBANK (VEB);
    • VTB BANK;
    • or to any person/entity established in Russia whose proprietary rights are directly or indirectly owned for more than 50 % by a listed entity;
  • Prohibition to sell, supply, transfer or export euro denominated banknotes to Russia or to any person/entity in Russia.

Council Decision (CFSP) 2022/351 of 1 March 2022 amending Decision 2014/512/CFSP and Council Regulation (EU) 2022/350 of 1 March 2022 amending Regulation (EU) No 833/2014[6]:

  • Prohibition to broadcast or to enable, facilitate or otherwise contribute to broadcast, any content by the following media channels:
    • RT- Russia Today English
    • RT- Russia Today UK
    • RT – Russia Today Germany
    • RT – Russia Today France
    • RT- Russia Today Spanish
    • Sputnik
  • Suspension of any broadcasting licence or authorisation, transmission and distribution arrangement with the listed entities.

3rd package of sanctions

Council Regulation (EU) 2022/394 of 9 March 2022 amending Regulation (EU) No 833/2014 and Council Decision (CFSP) 2022/395 of 9 March 2022 amending Decision 2014/512/CFSP[7]:

  • Restrictionson exports of maritime navigation goods and technology and on the provision of related services;
  • Prohibition of transactions related to the management of reserves as well as of assets of the Central Bank of Russia.

Council Implementing Regulation (EU) 2022/396 of 9 March 2022 implementing Regulation (EU) No 269/2014 and Council Decision (CFSP) 2022/397 of 9 March 2022 amending Decision 2014/145/CFSP [8]:

  • Individual sanctions for:
  • 146 members of the Russian Federation Council who ratified the Treaties of Friendship, Cooperation and Mutual Assistance between the Russian Federation and the Donetsk People’s Republic and the Luhansk People’s Republic;
  • 14 persons supporting and benefitting from the Government of the Russian Federation or providing a substantial source of revenue to it, or associated with listed persons or entities (oligarchs, prominent business people and their family members).

4th package of sanctions

Council Implementing Regulation (EU) 2022/427 of 15 March 2022 implementing Regulation (EU) No 269/2014 and Council Decision (CFSP) 2022/429 of 15 March 2022 amending Decision 2014/145/CFSP[9]:

  • Addition of 15 individuals and 9 entities to the list of persons/entities subject to restrictive measures set out in the Annex to Decision 2014/145/CFSP.

Council Regulation (EU) 2022/428 of 15 March 2022 amending Regulation (EU) No 833/2014 and Council Decision (CFSP) 2022/430 of 15 March 2022 amending Decision 2014/512/CFSP[10]:

  • Prohibition of all transactions with certain state-owned companies which are already subject to refinancing restrictions.
  • Prohibition of the provision of any credit rating services, as well as access to any subscription services in relation to credit rating activities, to any Russian person or entity.
  • Tightening of the export restrictions regarding dual-use goods and technology as well as goods and technology which might contribute to the technological enhancement of Russia’s defence and security sector;
    • The competent authorities of the Member States may only authorise the transfer of the above mentioned goods and technology or the provision of related technical or financial assistance to the persons/entities listed in Annex IV after having determined:
  • that they are necessary for the urgent prevention or mitigation of an event likely to have a serious and significant impact on human health and safety or the environment; or
  • that they are due under contracts concluded before 26 February 2022, or ancillary contracts necessary for the execution of such a contract, provided that the authorisation is requested before 1 May 2022);
  • Expansion of the list of persons connected to Russia’s defence and industrial base, which are subject to the mentioned export restrictions (dual-use, and defence and security sector related goods and technology).
  • Prohibition of new investments in the Russian energy sector;
  • Introduction of a comprehensive export restriction on equipment, technology and services for the energy industry in Russia, with the exception of nuclear industry and the downstream sector of energy transport.
  • Further trade restrictions concerning iron and steel;
  • Trade restrictions on certain luxury goods.

5th package of sanctions

Council Regulation (EU) 2022/576 of 8 April 2022 amending Regulation (EU) No 833/2014 and Council Decision (CFSP) 2022/578 of 8 April 2022 amending Decision 2014/512/CFSP[11]:

  • Prohibition to purchase, import or transfer coal and other solid fossil fuels into the EU, if they originate in Russia or are exported from Russia, as from 10 August 2022;
  • Extension of the prohibition to accept deposits from Russian nationals or persons/entities residing or established in Russia, if the total credit exceeds €100.000, as well as to provide crypto-asset wallet, account or custody services, if the total value of the crypto-assets exceeds €10.000;
  • Extension of prohibition to sell transferable securities issued after 12 April 2022 and to sell, supply, transfer or export banknotes denominated in any official currency of a Member State to Russia or to any person/entity in Russia or for use in Russia;
  • Prohibition to award or continue the execution of any public or concession contract to or with Russian nationals, persons/entities established in Russia or whose proprietary rights are directly or indirectly owned for more than 50 % by a listed entity (some exceptions may be authorized by the MS, e.g. civil nuclear facilities, natural gas and oil, intergovernmental cooperation in space programmes);
  • Prohibition to provide direct or indirect support, including financing and financial assistance or any other benefit under a Union, Euratom or Member State programme and contracts to any legal person, entity or body established in Russia with over 50 % public ownership or public control (with some exceptions, e.g. humanitarian purposes, intergovernmental cooperation in space programmes, civil nuclear capabilities, climate and environmental programmes);
  • Prohibition to act as a trustee or in similar capacities for, and prohibition to register, provide a registered office, business or administrative address as well as management services to, a trust or any similar legal arrangement having as a trustor or a beneficiary Russian persons or entities established in Russia or whose proprietary rights are directly or indirectly owned for more than 50 % by a Russian person/entity.
  • Prohibition to sell, supply, transfer, or export, directly or indirectly, goods and technology suited for use in oil refining and liquefaction of natural gas, aviation or the space industry, as well as jet fuel and fuel additives, and other goods listed in Annex I to Regulation (EU) 2022/576 (e.g. quantum computers and advanced semiconductors, high-end electronics, software, sensitive machinery), whether or not originating in the Union, to any person/entity in Russia or for use in Russia;
  • Prohibition after 16 April 2022 to provide access to EU ports to vessels registered under the flag of Russia (this applies also to vessels that have changed their Russian flag or their registration, to the flag or register of any other State after 24 February 2022. Some derogations are granted for pharmaceutical, medical, agricultural and food products, humanitarian aid, and energy);
  • Prohibition to purchase, import or transfer, directly or indirectly, goods which generate significant revenues for Russia as listed in Annex XXI to Regulation (EU) 2022/576 (e.g. wood, cement, fertilisers, seafood and liquor) or which could contribute in particular to the enhancement of Russia’s industrial capacities as listed in Annex XXIII to Regulation (EU) 2022/576, as from 10 July 2022;
  • Prohibition for any Russian road transport undertaking to transport goods by road within the EU, including in transit (some derogations are granted for certain products, e.g. pharmaceutical, medical, agricultural and food products, including wheat, and for road transport for humanitarian purposes);
  • Extension of the exemption from the prohibition to engage in transactions with certain State-owned entities as regards transactions for the purchase, import or transport of fossil fuels and certain minerals into Switzerland, the European Economic Area and the Western Balkans;
  • Extension of the exemption from the prohibition on transaction with certain Russian State-owned enterprises and their subsidiaries to countries in the European Economic Area and Switzerland as well as to the Western Balkans;

Council Regulation (EU) 2022/580 of 8 April 2022 amending Regulation (EU) No 269/2014, Council Implementing Regulation (EU) 2022/581 of 8 April 2022 implementing Regulation (EU) No 269/2014, and Council Decision (CFSP) 2022/582 of 8 April 2022 amending Decision 2014/145/CFSP [12]:

  • Addition of 216 individuals and 18 entities to the list of persons/entities subject to restrictive measures set out in Annex I to Regulation (EU) No 269/2014 and consisting in:
  • Leading businesspersons involved in economic sectors providing a substantial source of revenue to, and on persons supporting or benefitting from, the Government of the Russian Federation and on natural persons associated with those persons, including family members unduly benefitting from them (including the adult daughters of Vladimir Putin);
  • The Ministers and members of the ‘People’s Council’ of the so-called ‘Donetsk People’s Republic’ and ‘Luhansk People’s Republic’;
  • Companies supporting, materially or financially, or benefitting from the Government of the Russian Federation and materially or financially supporting actions which undermine or threaten the territorial integrity, sovereignty and independence of Ukraine (including the four following banks representing 23% of market share in the Russian banking sector: Otkritie FC Bank, Novikombank, Sovcombank, VTB Bank).
  • Introduction of further derogation options from the asset freeze and the prohibition to make funds and economic resources available to designated persons and entities.

6th package of sanctions

Council Implementing Regulation (EU) 2022/878 of 3 June 2022 implementing Regulation (EU) No 269/2014 and Council Decision (CFSP) 2022/883 of 3 June 2022 amending Decision 2014/145/CFSP[13]:

  • Addition of 65 individuals and 18 entities entities to the list of persons/entities subject to restrictive measures set out in Annex I to Regulation (EU) No 269/2014.

Council Regulation (EU) 2022/879 of 3 June 2022 amending Regulation (EU) No 833/2014 and Council Decision (CFSP) 2022/884 of 3 June 2022 amending Decision 2014/512/CFSP[14]:

  • Extended prohibition on the provision of specialised financial messaging (SWIFT) services to three additional Russian credit institutions, including the largest bank Sberbank;
  • Expanded list of persons connected to Russia’s defence and industrial base subject to tighter export restrictions regarding dual-use goods and technology, as well as goods and technology which might contribute to the technological enhancement of Russia’s defence and security sector;
  • Extended list of controlled items which might contribute to Russia’s military and technological enhancement or the development of its defence and security sector, whose export or supply to Russia is prohibited, to include inter alia additional chemicals that could be used in the process of manufacture of chemical weapons, as set out in Annex II to Council Regulation (EU) 2022/879;
  • Extended prohibition to broadcast to three additional Russian media outlets:
    • Rossiya RTR / RTR Planeta;
    • Rossiya 24 / Russia 24;
    • TV Centre International;
  • Import ban on all Russian seaborne crude oil and petroleum products, representing around 90% of EU oil imports from Russia, with some transitional periods and exceptions:
    • Such prohibition will not apply until 5 December 2022 to one-off transactions for near-term delivery, concluded and executed before that date, or to the execution of contracts for the purchase, import or transfer of goods falling under CN 2709 00 (Petroleum oils and oils obtained from bituminous minerals, crude) concluded before 4 June 2022; and until 5 February 2023 to those falling under CN 2710 (Petroleum oils and oils obtained from bituminous minerals, other than crude) concluded before 4 June 2022;
    • If the supply of crude oil by pipeline from Russia to a landlocked Member State is interrupted for reasons outside the control of that Member State, seaborne crude oil from Russia falling under CN 2709 00 may be imported into that Member State, by way of an exceptional temporary derogation;
    • Due to its specific geographical exposure, Bulgaria may authorise the execution until 31 December 2024 of contracts concluded before 4 June 2022 for the import of crude oil via maritime transport and of petroleum products.
    • Croatia may authorise until 31 December 2023 the purchase, import or transfer of vacuum gas oil falling under CN 2710 19 71 originating in Russia or exported from Russia, provided that the no alternative supply of vacuum gas oil is available; and the Commission has been notified at least two weeks prior to the authorization and has not objected within that period.
  • Prohibition to transfer, transport or sale crude oil falling under CN 2709 00 which is delivered by pipeline from Russia into Member States to Member States or to third countries (such prohibition will not apply to Czechia until 5 December 2023);
  • Prohibition to provide, directly or indirectly, technical assistance, brokering services or financing or financial assistance, related to the transport, including through ship-to-ship transfers, to third countries of Russian crude oil or petroleum products;
  • Prohibition to provide to Russia accounting, auditing, bookkeeping and tax consulting services, as well as business and management consulting and public relations services.

7th package of sanctions (maintenance and alignment sanctions package)

Council Decision (CFSP) 2022/1271 of 21 July 2022 amending Decision 2014/512/CFSP and Council Regulation (EU) 2022/1269 of 21 July 2022 amending Regulation (EU) No 833/2014[15]:

  • Prohibit the direct or indirect import, purchase or transfer of Russian-origin gold (Russia’s most significant export after energy), including jewellery, exported from Russia after the entry into force of the Decision;
  • Extend the port access ban to locks in order to ensure full implementation of the measure and avoid circumvention;
  • Expand the scope of the prohibition on accepting deposits to include those from legal persons, entities or bodies established in third countries and majority-owned by Russian nationals or natural persons residing in Russia;
  • Subject the acceptance of deposits for non-prohibited cross-border trade to a prior authorisation by the national competent authorities;
  • Prohibit to award or continue the execution of some public or concession contract, to or with:
    • a Russian or a person/entity residing or established in Russia;
    • a person/entity whose proprietary rights are directly or indirectly owned for more than 50 % by a Russian or a person/entity residing or established in Russia;
    • a person/entity acting on behalf or at the direction of an entity referred to in point (a) or (b) of this paragraph;
  • Allow the sharing of technical assistance with Russia for aviation goods and technology in order to guarantee technical standards in the framework of the International Civil Aviation Organization (ICAO);
  • Introduce an exemption from the prohibition to enter into any transactions with Russian public entities where this is necessary to ensure access to judicial, administrative or arbitral proceedings;
  • Extend the exemption from the prohibition to engage in transactions with certain State-owned entities as regards transactions for agricultural products – avoiding all measures which might lead to food insecurity around the globe – and the supply of oil and petroleum products to third countries.

Council Implementing Regulation (EU) 2022/1270 of 21 July 2022 implementing Regulation (EU) No 269/2014, Council Decision (CFSP) 2022/1272 of 21 July 2022 amending Decision 2014/145/CFSP, and Council Regulation (EU) 2022/1273 of 21 July 2022 amending Regulation (EU) No 269/2014[16]:

  • Addition of 48 people and 9 entities to the list of persons/entities subject to restrictive measures set out in Annex I to Regulation (EU) No 269/2014. These people and entities are senior members of the political or cultural establishment, high ranking military leaders and staff, Nightwolves and some of its members, propagandists and leading businesspersons;
  • Introduce further derogations from the asset freeze and the prohibition to make funds and economic resources available to designated persons and entities in order to:
    • prevent or mitigate an event likely to have a serious and significant impact on human health and safety or the environment;
    • avoid disruptions in the payment channels for agricultural products;
    • allow the orderly wind-down of operations, including correspondent banking relations, with one designated bank;
  • Oblige designated persons and entities with assets within the jurisdiction of a Member State to report these assets and to cooperate with the competent authority in the verification of this reporting;
  • Strengthen reporting requirements for EU operators with a view to preventing the breach and circumvention of the asset freezes.

Council Implementing Regulation (EU) 2022/1274 of 21 July 2022 implementing Regulation (EU) No 269/2014 and Council Decision (CFSP) 2022/1276 of 21 July 2022 amending Decision 2014/145/CFSP[17]:

  • Addition of six individuals and one entity involved in the recruitment of Syrian mercenaries to fight in Ukraine alongside Russian troops to the list of persons/entities subject to restrictive measures set out in Annex I to Regulation (EU) No 269/2014.

8th package of sanctions

Council Decision (CFSP) 2022/1907 of 6 October 2022 amending Decision 2014/145/CFSP concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, Council Regulation (EU) 2022/1905 of 6 October 2022, and Council Implementing Regulation (EU) 2022/1906 of 6 October 2022 implementing Regulation (EU) No 269/2014[18]:

  • Addition of 30 persons and 7 entities responsible for actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine to the list of persons, entities and bodies subject to restrictive measures set out in the Annex to Decision 2014/145/CFSP. This targets those involved in Russia’s occupation, illegal annexation, and sham “referenda” in the occupied territories/oblasts of Donetsk, Luhansk, Kherson, and Zaporizhzhia regions. It also includes individuals and entities working in the defence sector, such as high-ranking and military officials, as well as companies supporting the Russian armed forces;
  • New listing criterion for deterring sanctions circumvention: persons who facilitate the infringements of the prohibition against circumvention of sanctions will now be listed.

Council Decision (CFSP) 2022/1908 of 6 October 2022 amending Decision (CFSP) 2022/266 concerning restrictive measures in response to the recognition of the non-government controlled areas of the Donetsk and Luhansk oblasts of Ukraine and the ordering of Russian armed forces into those areas and Council Regulation (EU) 2022/1903 of 6 October 2022 amending Regulation (EU) 2022/263[19]:

  • Extension of the geographical scope of the restrictive measures to cover all the non-government controlled areas of Ukraine in the oblasts of Donetsk, Luhansk, Zaporizhzhia and Kherson.

Council Decision (CFSP) 2022/1909 of 6 October 2022 amending Decision 2014/512/CFSP concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine and Council Regulation (EU) 2022/1904 of 6 October 2022 amending Regulation (EU) No 833/2014[20]:

  • Ban on EU nationals from holding posts in the governing bodies of certain state-owned or State-controlled legal persons, entities or bodies;
  • Addition of the Russian Maritime Register of Shipping to the list of state-owned enterprises subject to a transaction ban, withdrawal of authorisations granted by Member State, and extension of the port access and lock ban in the territory of the Union to vessels certified by the Russian Maritime Register of Shipping;
  • Tightened prohibitions on crypto assets by banning all crypto-asset wallets, accounts, or custody services, irrespective of the amount of the wallet (previously allowed up to €10,000);
  • Extension of the existing prohibition on the provision of certain services to the Russian Federation, now including IT consultancy, legal advisory, architecture and engineering services;
    • ‘Legal advisory services’ covers: the provision of legal advice to customers in non-contentious matters, including commercial transactions, involving the application or interpretation of law; participation with or on behalf of clients in commercial transactions, negotiations and other dealings with third parties; and preparation, execution and verification of legal documents. ‘Legal advisory services’ does not include any representation, advice, preparation of documents or verification of documents in the context of legal representation services, namely in matters or proceedings before administrative agencies, courts or other duly constituted official tribunals, or in arbitral or mediation proceedings.
  • Prohibition on the sale, supply, transfer or export of firearms, their parts and essential components and ammunition. Goods subject to that prohibition are also covered by Regulation (EU) No 258/2012.

(In this context, Regulation (EU) No 833/2014 is to be treated as lex specialis and therefore, in the event of a conflict, takes precedence over Regulation (EU) No 258/2012);

  • Extension of the list of restricted items which might contribute to the Russian Federation’s military and technological enhancement or to the development of its defence and security sector, by including in that list certain chemical substances, nerve agents and goods which have no practical use other than for capital punishment, torture or other cruel, inhuman or degrading treatment or punishment, or which could be used for those purposes. Goods subject to that prohibition are also covered by Regulation (EU) 2019/125 (“Anti-torture Regulation“).

In this context, Regulation (EU) No 833/2014 is to be treated as lex specialis and therefore, in the event of a conflict, takes precedence over Regulation (EU) 2019/125.

  • Almost €7 billion worth of additional import restrictions: a ban on the import of Russian finished and semi-finished steel products (subject to a transition period for some semi-finished), machinery and appliances, plastics, vehicles, textiles, footwear, leather, ceramics, certain chemical products, and non-gold jewellery.
  • Ban on the export of coal including coking coal (which is used in Russian industrial plants), specific electronic components (found in Russian weapons), technical items used in the aviation sector, as well as certain chemicals.
  • Introduction of an exemption from the prohibition to provide technical assistance, brokering services or financing or financial assistance, related to the maritime transport to third countries of crude oil or petroleum products which originate in or are exported from Russia, purchased at or below a pre-established price cap agreed by the Price Cap Coalition. That exemption should mitigate adverse consequences on energy supply to third countries and reduce price surges driven by extraordinary market conditions, while limiting Russian oil revenues.

The exemption from the prohibition to provide maritime services is conditional upon the Council introducing the price cap into Annex XI to Decision 2014/512/CFSP. It would take effect after 5 December 2022 for crude and 5 February 2023 for refined petroleum products, after a further decision by the Council.

9th package of sanctions

Council Decision (CFSP) 2022/2478 of 16 December 2022 amending Decision 2014/512/CFSP concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine and Council Regulation (EU) 2022/2474 of 16 December 2022 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine[21]:

  • Extension of the list of restricted items which might contribute to Russia’s military and technological enhancement or the development of its defence and security sector, by adding aircraft engines and parts of engines, both manned and unmanned so including drone engines, further chemical and biological equipment, riot control agents, generators, toy drones, laptops, hard drives, IT components, night-vision and radio-navigation equipment, cameras and lenses;
  • Addition of 168 new entries to the list of entities connected to Russia’s military and industrial complex including certain Russian-controlled entities based in Crimea or Sevastopol due to a concrete risk that certain goods or technology are redirected from these Ukrainian regions to the Russian Federation (which brings the total number of entities sanctioned to 410);
  • Suspension of the broadcasting licences in the Union of Russian of four additional media outlets under the permanent control of the Russian leadership (i.e. NTV/NTV Mir, Rossiya 1, REN TV and Pervyi Kanal), and the prohibition against broadcasting their content;
  • Extension of the prohibition targeting new investments in the Russian energy sector by adding the Russian mining sector, with the exception of mining and quarrying activities involving certain critical raw materials.
  • Addition of the Russian Regional Development Bank to the list of Russian State-owned or controlled entities that aresubject to the transaction ban, and asset freeze against two additional Russian banks;
  • Ban on EU nationals from holding any posts on the governing bodies of all Russian State-owned or controlled legal persons, entities or bodies that are established in Russia;
  • Ban on the provision of EU advertising, market research and public opinion polling services, as well as product testing and technical inspection services to the Russian Federation;
  • Reporting obligation by no later than 27 May 2023 on deposits exceeding EUR 100 000 from legal persons, entities or bodies established in third countries and majority-owned by Russian nationals or natural persons residing in Russia. Updates regarding the amounts of such deposits shall be provided every 12 months.
  • Extension of the duration of the exemption from the prohibition to enter into any transactions with certain Russian state-owned entities until 30 September 2023, if such a transaction is strictly necessary for the wind-down of a joint venture or similar legal arrangement.

Council Decision (CFSP) 2022/2479 of 16 December 2022 amending Decision 2014/145/CFSP concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine and Council Regulation (EU) 2022/2475 of 16 December 2022 amending Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine[22]:

  • Introduction of a new deadline for the derogation allowing the divestment by a specific listed entity, so unfreezing assets of, and to making funds and economic resources available to, certain individuals who held a significant role in international trade in agricultural and food products, including wheat and fertilisers, prior to their listing.

Council Decision (CFSP) 2022/2477 of 16 December 2022 amending Decision 2014/145/CFSP concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, and Council Implementing Regulation (EU) 2022/2476 of 16 December 2022 implementing Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine[23]:

  • Addition of 141 persons and 49 entities responsible for actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine to list of persons subject to a freezing of their assets. This includes, inter alia, the Russian armed forces, as well as individual officers and defence industrial companies, members of the State Duma and Federation Council, ministers, Russian proxy authorities in occupied areas of Ukraine and political parties.

10th package of sanctions

Council Decision (CFSP) 2023/434 of 25 February 2023 amending Decision 2014/512/CFSP concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine and Council Regulation (EU) 2023/427 of 25 February 2023 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine:[24]

  • Prohibition as of 27 March 2023 to allow Russian nationals or natural persons residing in Russia to hold any posts in the governing bodies of the owners or operators of critical infrastructures[25], European critical infrastructure[26] and critical entities[27] (except for nationals of a Member State, of a country member of the European Economic Area or of Switzerland).
  • Prohibition to provide gas storage capacity in the Union to Russian nationals, natural persons residing in Russia or legal persons or entities established in Russia (with the exclusion of the part of LNG facilities).
    • However, the competent authorities may authorise the provision of storage capacity after having determined that it is necessary for ensuring critical energy supply within the Union. If so, the concerned MS shall inform the other Member States and the Commission of any granted authorisation within two weeks of the authorisation.
  • Prohibition of transit via the territory of Russia of dual-use goods and technology and of arms exported from the Union in order to minimise the risk of circumvention of restrictive measures.
  • Addition of 96 new entries to the list of entities connected to Russia’s military and industrial complex.
    • This is notably the case of several Iranian manufacturers of Unmanned Aerial Vehicles in reason of their direct connection with the Russian military and industrial complex.
  • Extension of the suspension of broadcasting licences in the Union of the following Russian media outlets under the permanent control of the Russian leadership and prohibition against broadcasting their content:
  • RT Arabic;
  • Sputnik Arabic.
  • Extension of the list of restricted items which might contribute to Russia’s military and technological enhancement or the development of its defence and security sector, by adding rare-earths and compounds, electronic integrated circuits and thermographic cameras, among others.
  • Further restrictions on exports of industrial goods which could contribute in particular to the enhancement of Russian industrial capacities.
  • Further bans on imports of goods which generate significant revenues for Russia by adding asphalt and synthetic rubber.
  • Introduction of an obligation for aircraft operators to notify non-scheduled flights to their competent authorities, which will then inform other member states, in order to avoid circumvention of the prohibition on any non-Russian-registered aircraft which is owned, chartered or controlled by any Russians from landing in, taking off from, or overflying, the territory of the Union.
  • Introduction of new and more detailed reporting obligations to ensure the effectiveness of the asset freeze prohibitions, notably on immobilized reserves and assets of the Central Bank of Russia.
  • Addition of 96 entities to the list of entities supporting directly Russia’s military and industrial complex in its war of aggression thereby imposing tighter export restrictions regarding dual-use goods and technology as well as goods and technology which might contribute to the technological enhancement of Russia’s defence and security sector.

Council Decision (CFSP) 2023/432 of 25 February 2023 amending Decision 2014/145/CFSP concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine and Council Implementing Regulation (EU) 2023/429 of 25 February 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:[28]

  • Addition of 87 individuals and 34 entities, including key decision makers, military leaders, military commanders of the Wagner group and drone manufacturers to the list of persons, entities and bodies subject to restrictive measures set out in the Annex to Decision 2014/145/CFSP.

In response to Belarus’s involvement in Russia’s unprovoked invasion against Ukraine, the EU has introduced the following new measures.

1st package of sanctions

Council Implementing Regulation (EU) 2022/353 of 2 March 2022 implementing Regulation (EU) No 269/2014 and Council Decision (CFSP) 2022/354 of 2 March 2022 amending Decision 2014/145/CFSP[29]:

  • Assets freezing and travel ban applicable to 22 listed Belarussian persons working for the Belarussian Ministry of Defence and armed forces.

Council Regulation (EU) 2022/355 of 2 March 2022 amending Regulation (EC) No 765/2006 and Council Decision (CFSP) 2022/356 of 2 March 2022 amending Decision 2012/642/CFSP[30]:

  • Restrictionson exports of dual-use goods and technology, whether or not originating in the Union,and on the provision of related services;
  • Restrictions on exports of certain goods and technology, whether or not originating in the Union, which might contribute to Belarus’s technological enhancement of its defence and security sector;
  • Prohibition to import cement, wood, iron and steel, and rubber products.

2nd package of sanctions

Council Regulation (EU) 2022/398 of 9 March 2022 amending Regulation (EC) No 765/2006 and Council Decision (CFSP) 2022/399 of 9 March 2022 amending Decision 2012/642/CFSP[31]:

  • Inclusion of crypto-assets under the scope of “transferable securities”
  • Prohibiting the transactions of Belarus’s central bank and freezing all its assets;
  • Prohibition to list and provide services as of 12 April 2022 on trading venues registered or recognised in the Union for the transferable securities of any person/entity established in Belarus and with over 50 % public ownership;
  • Prohibition to provide public financing or financial assistance for trade with, or investment in, Belarus;
  • Prohibition to accept any deposits from Belarusian nationals or persons/entities residing or established in Belarus, if the total value of deposits per credit institution exceeds EUR 100 000;
  • Prohibition to sell euro denominated transferable securities issued after 12 April 2022 and to sell, supply, transfer or export euro denominated banknotes to any Belarusian national or persons/entities residing or established in Belarus;
  • Prohibition to provide SWIFT services to:
  • Belagroprombank;
  • Bank Dabrabyt;
  • Development Bank of the Republic of Belarus;
  • or to any person/entity established in Belarus whose proprietary rights are directly or indirectly owned for more than 50 % by a listed entity.

3rd package of sanctions

Council Regulation (EU) 2022/577 of 8 April 2022 amending Regulation (EC) No 765/2006 and Council Decision (CFSP) 2022/579 of 8 April 2022 amending Decision 2012/642/CFSP[32]:

  • Extension of the prohibition to sell transferable securities and to sell, supply, transfer or export banknotes denominated in any official currency of a Member State to Belarus;
  • Prohibition for any Belarusian road transport undertaking to transport goods by road within the EU, including in transit.

4th package of sanctions

Council Implementing Regulation (EU) 2022/876 of 3 June 2022 implementing Article 8a(1) of Regulation (EC) No 765/2006 and Council Implementing Decision (CFSP) 2022/881 of 3 June 2022 implementing Decision 2012/642/CFSP[33]:

  • Addition of 12 individuals and eight entities to the list of persons/entities subject to restrictive measures set out in Annex I to Regulation (EC) No 765/2006.

Council Regulation (EU) 2022/877 of 3 June 2022 amending Regulation (EC) No 765/2006 and Council Decision (CFSP) 2022/882 of 3 June 2022 amending Decision 2012/642/CFSP[34]:

  • Expanded list of entities (25) subject to restrictions with regard to authorisations for the sale, supply, transfer or export of dual-use goods and technology, and goods and technology which might contribute to Belarus’s military and technological enhancement, or to the development of its defence and security sector, as set out in Annex I to the Council Regulation (EU) 2022/877;
  • Expanded list of Belarusian credit institutions (4) and their Belarusian subsidiaries subject to restrictive measures with regard to the provision of specialised financial messaging (SWIFT) services, as set out in Annex II to the Council Regulation (EU) 2022/877.

5th package of sanctions

Council Decision (CFSP) 2023/421 of 24 February 2023 amending Decision 2012/642/CFSP concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine and Council Implementing Regulation (EU) 2023/419 of 24 February 2023 implementing Article 8a of Regulation (EC) No 765/2006 concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine:[35]

  • Extension of the restrictive measures linked to internal repression in Belarus and regime’s support for the war against Ukraine for another year, thus applying until 28 February 2024.
  • Modification of the entries relating to 21 natural and 2 legal persons to the list of persons/entities subject to restrictive measures set out in Annex I to Regulation (EC) No 765/2006, which currently apply to 195 individuals and 34 entities, including Alexandr Lukashenko.

[1] Council Decision 2014/145/CFSP of 17 March 2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, OJ L 78, 17.3.2014, p. 16–21, and Council Regulation (EU) No 269/2014 of 17 March 2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, OJ L 78, 17.3.2014, p. 6–15; Council Decision 2014/512/CFSP of 31 July 2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine OJ L229, 31.7.2014, p. 13–17, and Council Regulation (EU) No 833/2014 of 31 July 2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, OJ L 229, 31.7.2014, p. 1–11.

[2] Council Decision (CFSP) 2022/264 of 23 February 2022 amending Decision 2014/512/CFSP concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, OJ L42I , 23.2.2022, p. 95–97, and Council Regulation (EU) 2022/262 of 23 February 2022 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, OJ L 42I , 23.2.2022, p. 74–76;

Council Decision (CFSP) 2022/265 of 23 February 2022 amending Decision 2014/145/CFSP concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, OJ L 42I , 23.2.2022, p. 98–108, and Council Regulation (EU) 2022/259 of 23 February 2022 amending Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, OJ L 42I , 23.2.2022, p. 1–2;

Council Decision (CFSP) 2022/266 of 23 February 2022 concerning restrictive measures in response to the recognition of the non-government controlled areas of the Donetsk and Luhansk oblasts of Ukraine and the ordering of Russian armed forces into those areas, OJ L 42I , 23.2.2022, p. 109–113, and Council Regulation (EU) 2022/263 of 23 February 2022 concerning restrictive measures in response to the recognition of the non-government controlled areas of the Donetsk and Luhansk oblasts of Ukraine and the ordering of Russian armed forces into those areas, OJ L 42I , 23.2.2022, p. 77–94;

Council Decision (CFSP) 2022/267 of 23 February 2022 amending Decision 2014/145/CFSP concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, OJ L 42I , 23.2.2022, p. 114–172;

Council Implementing Regulation (EU) 2022/260 of 23 February 2022 implementing Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, OJ L 42I , 23.2.2022, p. 3–14;

Council Implementing Regulation (EU) 2022/261 of 23 February 2022 implementing Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, OJ L 42I , 23.2.2022, p. 15–73;

Council Decision (CFSP) 2022/327 of 25 February 2022 amending Decision 2014/512/CFSP concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, OJ L 48, 25.2.2022, p. 1–16, and Council Regulation (EU) 2022/328 of 25 February 2022 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, OJ L 49, 25.2.2022, p. 1–140;

Council Decision (CFSP) 2022/329 of 25 February 2022 amending Decision 2014/145/CFSP concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, OJ L 50, 25.2.2022, p. 1–3, and Council Regulation (EU) 2022/330 of 25 February 2022 amending Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, OJ L 51, 25.2.2022, p. 1–2;

Council Decision (CFSP) 2022/331 of 25 February 2022 amending Decision 2014/145/CFSP concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, OJ L 52, 25.2.2022, p. 1–44;

Council Implementing Regulation (EU) 2022/332 of 25 February 2022 implementing Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, OJ L 53, 25.2.2022, p. 1–44;

Council Decision (EU) 2022/333 of 25 February 2022 on the partial suspension of the application of the Agreement between the European Community and the Russian Federation on the facilitation of the issuance of visas to the citizens of the European Union and the Russian Federation, OJ L 54, 25.2.2022, p. 1–3;

Council Regulation (EU) 2022/334 of 28 February 2022 amending Council Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, OJ L 57, 28.2.2022, p. 1–3;

Council Decision (CFSP) 2022/335 of 28 February 2022 amending Decision 2014/512/CFSP concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, OJ L 57, 28.2.2022, p. 4–6;

Council Implementing Regulation (EU) 2022/336 of 28 February 2022 implementing Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, OJ L 58, 28.2.2022, p. 1–18;

Council Decision (CFSP) 2022/337 of 28 February 2022 amending Decision 2014/145/CFSP concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, OJ L 59, 28.2.2022, p. 1–17.

[3] Decision (EU) 2022/313 of the European Parliament and of the Council of 24 February 2022 providing macro-financial assistance to Ukraine, OJ L 55, 28.2.2022, p. 4–11.

[4] Council Decision (CFSP) 2022/338 of 28 February 2022 on an assistance measure under the European Peace Facility for the supply to the Ukrainian Armed Forces of military equipment, and platforms, designed to deliver lethal force, OJ L 60, 28.2.2022, p. 1–4; and Council Decision (CFSP) 2022/339 of 28 February 2022 on an assistance measure under the European Peace Facility to support the Ukrainian Armed Forces, OJ L 61, 28.2.2022, p. 1–4.

[5] Council Regulation (EU) 2022/345 of 1 March 2022 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, OJ L 63, 2.3.2022, p. 1–4;

Council Decision (CFSP) 2022/346 of 1 March 2022 amending Decision 2014/512/CFSP concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, OJ L 63, 2.3.2022, p. 5–7.

[6] Council Regulation (EU) 2022/350 of 1 March 2022 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, OJ L 65, 2.3.2022, p. 1–4;

Council Decision (CFSP) 2022/351 of 1 March 2022 amending Decision 2014/512/CFSP concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, OJ L 65, 2.3.2022, p. 5–7.

[7] Council Regulation (EU) 2022/394 of 9 March 2022 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, OJ L 81, 9.3.2022, p. 1–7;

Council Decision (CFSP) 2022/395 of 9 March 2022 amending Decision 2014/512/CFSP concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, OJ L 81, 9.3.2022, p. 8–11.

[8] Council Implementing Regulation (EU) 2022/396 of 9 March 2022 implementing Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, OJ L 80, 9.3.2022, p. 1–30;

Council Decision (CFSP) 2022/397 of 9 March 2022 amending Decision 2014/145/CFSP concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, OJ L 80, 9.3.2022, p. 31–60.

[9] Council Implementing Regulation (EU) 2022/427 of 15 March 2022 implementing Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, OJ L 87I, 15.3.2022, p. 1–12;

Council Decision (CFSP) 2022/429 of 15 March 2022 amending Decision 2014/145/CFSP concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, OJ L 87I, 15.3.2022, p. 44–55.

[10] Council Regulation (EU) 2022/428 of 15 March 2022 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, OJ L 87I, 15.3.2022, p. 13–43;

Council Decision (CFSP) 2022/430 of 15 March 2022 amending Decision 2014/512/CFSP concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, OJ L 87I, 15.3.2022, p. 56–63.

[11] Council Regulation (EU) 2022/576 of 8 April 2022 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, OJ L 111, 8.4.2022, p. 1–66;

Council Decision (CFSP) 2022/578 of 8 April 2022 amending Decision 2014/512/CFSP concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, OJ L 111, 8.4.2022, p. 70–80.

[12] Council Regulation (EU) 2022/580 of 8 April 2022 amending Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, OJ L 110, 8.4.2022, p. 1–2;

Council Implementing Regulation (EU) 2022/581 of 8 April 2022 implementing Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, OJ L 110, 8.4.2022, p. 3–54;

Council Decision (CFSP) 2022/582 of 8 April 2022 amending Decision 2014/145/CFSP concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, OJ L 110, 8.4.2022, p. 55–105.

[13] Council Implementing Regulation (EU) 2022/878 of 3 June 2022 implementing Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, OJ L 153, 3.6.2022, p. 15–52;

Council Decision (CFSP) 2022/883 of 3 June 2022 amending Decision 2014/145/CFSP concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, OJ L 153, 3.6.2022, p. 92–127.

[14] Council Regulation (EU) 2022/879 of 3 June 2022 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, OJ L 153, 3.6.2022, p. 53–74;

Council Decision (CFSP) 2022/884 of 3 June 2022 amending Decision 2014/512/CFSP concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, OJ L 153, 3.6.2022, p. 128–138.

[15] Council Regulation (EU) 2022/1269 of 21 July 2022 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, OJ L 193, 21.7.2022, p. 1–132;

Council Decision (CFSP) 2022/1271 of 21 July 2022 amending Decision 2014/512/CFSP concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, OJ L 193, 21.7.2022, p. 196–218.

[16] Council Implementing Regulation (EU) 2022/1270 of 21 July 2022 implementing Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, OJ L 193, 21.7.2022, p. 133–195;

Council Decision (CFSP) 2022/1272 of 21 July 2022 amending Decision 2014/145/CFSP concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, OJ L 193, 21.7.2022, p. 219–285;

Council Regulation (EU) 2022/1273 of 21 July 2022 amending Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, OJ L 194, 21.7.2022, p. 1–4.

[17] Council Implementing Regulation (EU) 2022/1274 of 21 July 2022 implementing Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, OJ L 194, 21.7.2022, p. 5–7;

Council Decision (CFSP) 2022/1276 of 21 July 2022 amending Decision 2014/145/CFSP concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, OJ L 194, 21.7.2022, p. 11–14.

[18] Council Decision (CFSP) 2022/1907 of 6 October 2022 amending Decision 2014/145/CFSP concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, OJ L 259I , 6.10.2022, p. 98–117;

Council Regulation (EU) 2022/1905 of 6 October 2022 amending Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, OJ L 259I , 6.10.2022, p. 76–78;

Council Implementing Regulation (EU) 2022/1906 of 6 October 2022 implementing Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, OJ L 259I, 6.10.2022, p. 79–97.

[19] Council Decision (CFSP) 2022/1908 of 6 October 2022 amending Decision (CFSP) 2022/266 concerning restrictive measures in response to the recognition of the non-government controlled areas of the Donetsk and Luhansk oblasts of Ukraine and the ordering of Russian armed forces into those areas, OJ L 259I, 6.10.2022, p. 118–121;

Council Regulation (EU) 2022/1903 of 6 October 2022 amending Regulation (EU) 2022/263 concerning restrictive measures in response to the recognition of the non-government controlled areas of the Donetsk and Luhansk oblasts of Ukraine and the ordering of Russian armed forces into those areas, OJ L 259I, 6.10.2022, p. 1–2.

[20] Council Decision (CFSP) 2022/1909 of 6 October 2022 amending Decision 2014/512/CFSP concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, OJ L 259I, 6.10.2022, p. 122–134;

Council Regulation (EU) 2022/1904 of 6 October 2022 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, OJ L 259I , 6.10.2022, p. 3–75.

[21] Council Decision (CFSP) 2022/2478 of 16 December 2022 amending Decision 2014/512/CFSP concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, OJ L 322I, 16.12.2022, p. 614–686;

Council Regulation (EU) 2022/2474 of 16 December 2022 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, OJ L 322I, 16.12.2022, p. 1–314.

[22] Council Decision (CFSP) 2022/2479 of 16 December 2022 amending Decision 2014/145/CFSP concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, OJ L 322I, 16.12.2022, p. 687–688;

Council Regulation (EU) 2022/2475 of 16 December 2022 amending Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, OJ L 322I, 16.12.2022, p. 315–317.

[23] Council Decision (CFSP) 2022/2477 of 16 December 2022 amending Decision 2014/145/CFSP concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, OJ L 322I, 16.12.2022, p. 466–613;

Council Implementing Regulation (EU) 2022/2476 of 16 December 2022 implementing Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, OJ L 322I, 16.12.2022, p. 318–465.

[24] Council Decision (CFSP) 2023/434 of 25 February 2023 amending Decision 2014/512/CFSP concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, OJ L 59I , 25.2.2023, p. 593–641;

Council Regulation (EU) 2023/427 of 25 February 2023 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, OJ L 59I , 25.2.2023, p. 6–274.

[25] As defined in Directive 2008/114/EC and Directive (EU) 2022/2557.

[26] As defined in Council Directive 2008/114/EC.

[27] As defined in Directive (EU) 2022/2557. Directive (EU) 2022/2557 establishes an obligation for Member States to identify by 17 July 2026 in their national law the critical entities for the sectors and subsectors set out in the Annex thereto. Therefore, as from 17 July 2026, the new prohibition on holding any posts in the governing bodies will concern all the critical entities identified or designated as such by Member States.

[28] Council Decision (CFSP) 2023/432 of 25 February 2023 amending Decision 2014/145/CFSP concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, OJ L 59I , 25.2.2023, p. 437–582;                                                                                      

Council Implementing Regulation (EU) 2023/429 of 25 February 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, OJ L 59I , 25.2.2023, p. 278–422.

[29] Council Implementing Regulation (EU) 2022/353 of 2 March 2022 implementing Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, OJ L 66, 2.3.2022, p. 1–13;

Council Decision (CFSP) 2022/354 of 2 March 2022 amending Decision 2014/145/CFSP concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, OJ L 66, 2.3.2022, p. 14–26.

[30] Council Regulation (EU) 2022/355 of 2 March 2022 amending Regulation (EC) No 765/2006 concerning restrictive measures in view of the situation in Belarus, OJ L 67, 2.3.2022, p. 1–102;

Council Decision (CFSP) 2022/356 of 2 March 2022 amending Decision 2012/642/CFSP concerning restrictive measures in view of the situation in Belarus, OJ L 67, 2.3.2022, p. 103–111.

[31] Council Regulation (EU) 2022/398 of 9 March 2022 amending Regulation (EC) No 765/2006 concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine, OJ L 82, 9.3.2022, p. 1–8;

Council Decision (CFSP) 2022/399 of 9 March 2022 amending Decision 2012/642/CFSP concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine, OJ L 82, 9.3.2022, p. 9–13.

[32] Council Regulation (EU) 2022/577 of 8 April 2022 amending Regulation (EC) No 765/2006 concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine, OJ L 111, 8.4.2022, p. 67–6;

Council Decision (CFSP) 2022/579 of 8 April 2022 amending Decision 2012/642/CFSP concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine, OJ L 111, 8.4.2022, p. 81–83.

[33] Council Implementing Regulation (EU) 2022/876 of 3 June 2022 implementing Article 8a(1) of Regulation (EC) No 765/2006 concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine, OJ L 153, 3.6.2022, p. 1–10;

Council Implementing Decision (CFSP) 2022/881 of 3 June 2022 implementing Decision 2012/642/CFSP concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine, OJ L 153, 3.6.2022, p. 77–87.

[34] Council Regulation (EU) 2022/877 of 3 June 2022 amending Regulation (EC) No 765/2006 concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine, OJ L 153, 3.6.2022, p. 11–14;

Council Decision (CFSP) 2022/882 of 3 June 2022 amending Decision 2012/642/CFSP concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine, OJ L 153, 3.6.2022, p. 88–91.

[35] Council Decision (CFSP) 2023/421 of 24 February 2023 amending Decision 2012/642/CFSP concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine, OJ L 61, 27.2.2023, p. 41–57;

Council Implementing Regulation (EU) 2023/419 of 24 February 2023 implementing Article 8a of Regulation (EC) No 765/2006 concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine, OJ L 61, 27.2.2023, p. 20–36.

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