EU’s 15th sanctions package and hybrid sanctions regime target parties serving Russia’s interests
In response to Russia’s continuing war of aggression and attacks on civilian targets in Ukraine, the EU’s 15th sanctions package targets individuals and entities that exert military, political or economic influence in Russia. The sanctions are also intended to intervene in the operation of the shadow fleet. The EU warns businesses of the deteriorating business environment in Russia and calls on them to consider winding down businesses in Russia and not to start new businesses there. The EU will make its first listings in the new sanctions framework, the ‘hybrid sanctions regime’, established in response to Russia’s destabilising actions abroad. The listings will include individuals who have contributed to Russia’s destabilising policy in Member States or third countries.
15th sanctions package
The individuals added by the EU to the sanctions list are representatives of the Russian armed forces, political actors, information influencers and opinion leaders in Russian society and business leaders supporting or benefiting from the Russian government. In addition, third-country companies and individuals (from countries such as China) who have been assessed to promote the circumvention of sanctions on Russia and support Russia’s war industry will be added to the list. The EU is adding non-EU tankers to the sanctions list to target what is known as a ‘shadow fleet’, which is circumventing the oil price cap mechanism. In addition, the EU is expanding the export ban list by adding to it 33 entities associated with Russia’s military industry in countries including Russia, China, India and the United Arab Emirates, in particular for circumventing sanctions imposed on the export of drones and missiles.
The EU will prohibit the recognition or enforcement in the Union of recent fines imposed by Russian courts on EU businesses. The EU considers that the way Russian courts issue anti suit injunctions (preventing the opposing party from commencing or continuing a proceeding in another state or forum) and disproportionately high financial penalties clearly violates established international principles and practices for resolving international business disputes.
The EU warns economic operators that Russia is a country where the rule of law is not applied anymore and where assets of companies from Member States can be targeted. The EU calls on companies to consider winding down businesses in Russia and/or not to start new businesses there.
The package extends certain derogations, for example to imports of Russian oil, and it extends and adds certain derogations to the sanctions regulations. The EU extends the derogation that enables EU businesses to exit Russia. A derogation will be added to the Council Decision (EU) No 269/2014 on individual restrictive measures to make it possible to grant an exemption for the sale of the shares of the Helsinki Halli Oy. The 15th sanctions package also includes additions and clarifications relating to frozen assets and securities issued by Russia.
Listings for hybrid sanctions regime
In response to Russia's destabilising actions, the EU has established a hybrid sanctions regime to target individuals and entities engaged in actions and policies of the Russian government, which undermine the fundamental values of the EU and its Member States, their security, independence and integrity, as well as those of international organisations and third countries. The EU’s listing includes individuals who have participated in the implementation of Russia’s disinformation campaigns in the EU, the United States, Ukraine, Africa and Latin America.
Ministry for Foreign Affairs recommends introductory course to sanctions to companies
The Ministry for Foreign Affairs has prepared a comprehensive introductory course to sanctions in cooperation with the authorities and businesses. The course has sections for companies to develop their expertise in sanctions. The Ministry recommends that both corporate management and staff complete the introductory course.
The course is open to everyone free of charge and can be found on the eOppiva virtual education platform in Finnish and in English.
Companies should also familiarise themselves with the expert guidance for companies on how to detect and prevent circumvention of sanctions published by the Ministry for Foreign Affairs and with the G7 Industry Guidance on preventing sanctions evasion published by the Commission.
The individual and corporate sanctions regime
- Council desicion (CFSP) 2024/3182
- Council Regulation (EU) 2024/3189
- Council Implementing Regulation (EU) 2024/3183
The sectoral sanctions regime
The hybrid sanctions regime
More information:
- Pia Sarivaara, Sanctions Coordinator, Unit for Sanctions, Ministry for Foreign Affairs, tel. +358 295 350 660
-
The email addresses of the Ministry for Foreign Affairs are in the format [email protected].