European Union Trade Sanctions on Russia

• Jurisdiction: European Union
• Citation: Vol. 1 No. 1
• Publication year: 2024

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Konstantin Bureiko, Alan Kartashkin, Jane Shvets, and Anastasia Magid ^*

Following Russia's invasion of Ukraine on February 24, 2022, the European Union and other nations imposed various sanctions and export controls. This article provides an overview of the trade sanctions imposed by the European Union on Russia.

Export Restrictions

The European Union implemented a number of sanctions restricting Russian access to EU goods and technologies, including the following groups of export restrictions:

■ Energy sector and oil refinery-related products,
■ An expansion of the restrictions on dual-use goods and technology,
■ Advanced technology,
■ Aircraft,
■ Goods that contribute to the enhancement of Russian industrial capacities, and
■ Luxury products.

Energy Sector and Oil Refinery-Related Products

The European Union has significantly strengthened restrictions on the provision of certain goods and technology that are suited to certain categories of exploration and production projects to any person or entity in Russia or for use in Russia, in both cases including its Exclusive Economic Zone and Continental Shelf. Since August 1, 2014, the European Union has required exporters to have licenses before exporting these goods and technologies to Russian persons. The new requirements make it a prohibition to sell, supply, transfer, and export these goods and technology except for narrow exemptions and prohibits provision of related

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financing or financial assistance. The energy-related prohibition was later extended to also apply to goods and technology suited for oil refining and liquefaction of natural gas.

On June 23, 2023, ¹ the European Union extended this restriction to cover the sale, licensing, or transfer of intellectual property rights or trade secrets related to energy sector and oil refining goods to any person or entity in Russia or for use in Russia.

Dual-Use Goods

The sale, supply, transfer, or export to Russia of dual-use goods and technology, including the provision of related technical services, brokering services, financing, or financial assistance is now prohibited (with some exemptions).

The European Union prohibited transit through Russia of EU-exported dual-use goods and technology to avoid circumvention.

On June 23, 2023, the European Union extended this restriction to cover the sale, licensing, or transfer of intellectual property rights or trade secrets related to dual-use goods and technology to any person or entity in Russia or for use in Russia.

Advanced Technology and Maritime Technology

In addition, the sale, supply, transfer, or export to Russia of goods and technology that might contribute to Russia's military and technological enhancement, or the development of the defense and security sector (including semiconductors), including the provision of related technical services, brokering services, financing, or financial assistance is also prohibited (with some exemptions).

The above prohibitions include, among others, the following goods and technology:

■ Coal and coke of coal, chemicals, and goods that can be used for capital punishment, torture, or other inhumane treatment;
■ Electronics, specialized vehicles, machine parts and spare parts for trucks and jet engines, as well as goods for the construction sector that can be directed to Russia's military, such as antennas or cranes; and
■ Electronic components used in Russian weapons systems retrieved on the battlefield, such as drones, missiles, and

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helicopters, as well as specific rare earth materials, electronic integrated circuits, and thermal cameras.

There is also a ban on the sale and supply of maritime navigation goods and technology whether or not originating in the European Union to any natural or legal person in Russia, for use in Russia, or for use on Russian-flagged vessels subject to a humanitarian exemption. This ban also applies to the provision of technical assistance, brokering services, provision, manufacture, and maintenance of these goods, as well as financing the sale and supply of these goods or related services.

The sale, supply, transfer, or export of civilian firearms and their components and ammunition, military vehicles and equipment, paramilitary equipment and spare parts is also prohibited.

On June 23, 2023, the European Union prohibited transit via the territory of Russia of goods and technology that contribute to Russia's military and technological enhancement or to the development of its defense and security sector unless certain exemptions apply or licenses are obtained.

Further, the European Union extended this restriction to cover the sale, licensing, or transfer of intellectual property rights or trade secrets related to military and security enhancement goods and technology, maritime equipment, and firearms, to any person or entity in Russia or for use in Russia.

Finally, a new licensing ground allows to request an authorization to deal with military and security enhancement goods intended for the exclusive use and under the full control of the authorizing Member State and in order to fulfill its maintenance obligations in areas that are under a long-term lease agreement between that Member State and the Russian Federation.

Aircraft

There are three restrictive measures currently in place in relation to aircraft and the aviation sector:

1. Prohibition on the sale, supply, transfer, or export of goods and technology suited for use in the aviation and space industry, including the sale of all aircrafts, spare parts, and equipment to Russian airlines, including aircraft and drone engines and their parts;

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2. Prohibition on the provision of related technical and financial assistance, including the overhaul, repair, inspection, replacement, modification, or defect rectification of an aircraft or component, with the exception of pre-flight inspection; and
3. Prohibition on the provision of insurance and reinsurance, and maintenance services, related to those goods and technology.

On June 23, 2023, the European Union extended this...