Information on sanctions in respect of the situation in Ukraine

1. EU Guidance / FAQs:
2. Sanctions Implementation in Ireland
3. Sanctions Adopted on 25 February
4. Sanctions Adopted on 16 December
5. Sanctions Adopted on 6 October
6. Sanctions Adopted on 21 July
7. Sanctions Adopted on 3 June

8. Sanctions Adopted on 8 April
9. Sanctions Adopted on 15 March
10. Sanctions Adopted on 9 March
11. Sanctions Adopted on 1-2 March
12. Sanctions Adopted on 28 February
13. Sanctions Adopted on 25 February 2022
14. Sanctions Adopted on 23 February

EU Guidance / FAQs:

The European Council information webpage on EU restrictive measures against Russia over Ukraine is available here. This provides an overview of all EU sanctions adopted in response to Russian actions in Ukraine since 2014, including a timeline.

European Commission guidance on sanctions adopted following Russia’s military aggression against Ukraine is available here. This webpage includes a comprehensive section on frequently asked questions, particularly regarding sanctions implementation. It is updated by the Commission on a regular basis.

Sanctions Implementation in Ireland

EU sanctions are legally binding on all natural and legal persons in Ireland and the EU. EU Council Regulations have direct effect, and must therefore be complied with in the same way as domestic Irish legislation.

Derogations to EU sanctions are provided for in the legal acts. Individuals and entities may apply under these derogations for authorisation to take actions otherwise prohibited by the sanctions. Requests for authorisations should be made to the relevant competent authority:

Department of Foreign Affairs : see here

Department of Enterprise, Trade and Employment : exportcontrol@enterprise.gov.ie

Central Bank of Ireland : sanctions@centralbank.ie

Sanctions Adopted on 25 February

On 25 February 2023, the EU adopted its tenth package of sectoral and individual sanctions in response to Russia’s illegal aggression against Ukraine. 24 February marked one year since Russia's full-scale invasion of Ukraine and 9 years since the beginning of Russia's illegal invasion and occupation of Ukrainian territory.

This tenth package of sanctions contains new individual listings as well as extensive sectoral sanctions, including further export bans worth more than €11 billion, depriving the Russian economy of critical technology and industrial goods. The package also steps up enforcement and anti-circumvention measures, introducing a new reporting obligation on Russian Central Bank assets. The new measures were introduced to two existing EU sanctions regimes.

1) New measures were introduced to the existing Russia Sectoral Sanctions Regime (Council Regulation 833/2014). These are summarised as follows:

a) Additional EU export bans

New export bans have been introduced on sensitive dual-use and advanced technologies that contribute to Russia's military capabilities and technological enhancement. These restrictions apply to electronic components used in Russian weapons systems (drones, missiles, helicopters and other vehicles), as well as to specific rare earths and thermal cameras with military applications. An additional 96 entities associated with Russia's military-industrial complex are listed in this package, bringing the total number of listed military end-users to 506. These listings include seven Iranian entities.
Australia, Canada and New Zealand and Norway have been added to the list of the EU’s partner countries that are applying a set of export control measures substantially equivalent to those set out in Council Regulation 833/2014.
There is a prohibition on the transit of dual-use goods and firearms via the territory of Russia to third countries.
Additional export bans are now also imposed on goods that can be easily redirected to be used to support the Russian war effort including:

-Vehicles: heavy trucks not yet banned (and their spare parts), semi-trailers, and special vehicles such as snowmobiles;

-Goods easily directed to the Russian military including electric generators, binoculars, radars and compasses;

-Construction goods such as bridges, structures for buildings, fork-lifts trucks and cranes;

-Goods that are critical for the functioning of Russian industrial capacity (electronics, machine parts, pumps and machinery for working metals);

-Goods used in the aviation industry (turbojets).

b) Additional imports bans into the EU

This new package imposes import bans on Russian high-revenue goods such as bitumen, synthetic rubber and carbon. These new import bans cover EU imports worth almost EUR 1.3 billion, adding to the €90 billion worth of imports already sanctioned, representing altogether 58% of the EU's 2021 imports.

c) Other sectoral measures

Russian nationals are banned from serving on governing bodies of Member States' critical infrastructure companies;
Russian nationals and entities are prohibited from booking gas storage capacity in the EU;
Certain derogations have been introduced to facilitate divestment from Russia by EU operators;
Private flights from Russia to the EU, directly or via third countries, must be notified to the national competent authorities of the destination country in advance;
New rules have been introduced on the release by Member State customs authorities of goods that had already been presented to customs authorities when they became subject to such restrictions.
An exemption is introduced to allow the provision of pilot services necessary for maritime safety; and
Two additional Russian media outlets have been added to the media ban.

2) New measures were also introduced to the existing sanctions regime in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine (Council Regulation 269/2014). These are summarised as follows:

The EU has added 87 individuals and 34 entities to the sanctions list, including further Russian decision-makers, senior Government officials, military leaders, proxy authorities in occupied areas of Ukraine, key figures involved in the kidnapping of Ukrainian children, propagandists, three Russian banks, and Iranian suppliers of drones. The individuals and entities listed are subject to an assets freeze and a prohibition to make economic resources available to them, and the individuals are subject to a travel ban.
The EU has introduced more detailed reporting obligations on funds and economic resources belonging to listed individuals and entities which have been frozen or were subject to any move shortly before their listing.

Further information on this new sanctions package is available here and more information on the new listings can be found here.

Sanctions Adopted on 16 December

On 16 December, the EU adopted its ninth package of sectoral and individual measures in response to Russia’s continuing war of aggression against Ukraine and the gravity of the current escalation against civilians and civilian infrastructure. These new measures are intended to increase the pressure on Russia and its government. The new measures were introduced to two existing EU sanctions regimes.

1) New measures were introduced to the existing Russia Sectoral Sanctions Regime (Council Regulation 833/2014). These are summarised below.

a) Trade measures:

An extension of the list of restricted items, the sale, supply, transfer or export of which might contribute to Russia’s military and technological enhancement or the development of its defence and security sector, to include a) drone engines; b) further chemical and biological equipment; c) riot control agents; and d) electronic components.
An expansion of the list of entities connected to Russia’s military and industrial complex on whom tighter export restrictions regarding dual-use goods and technology are imposed (168 new entities added).
An extension of the list of restricted items, the sale, supply, transfer or export of which is prohibited, covering goods and technology suited for use in aviation and the space industry.
A new a derogation to allow the provision of technical assistance related to the use of goods and technology in aviation or the space industry when this is necessary to avoid collision between satellites, or their unintended re-entry into the atmosphere.
An extension of the list of restricted items, the sale, supply, transfer or export of which might contribute to the enhancement of Russia’s industrial capabilities, to include a) generators; b) toy drones; c) laptops; d) hard drives; e) IT components; f) night-vision; and g) radio-navigation equipment, cameras and lenses.
A new derogation, which is temporary and limited, from the import and export prohibitions in the Regulations, in order to facilitate exiting the Russian market.
A prohibition on the provision of market research and public opinion polling services, technical testing and analysis services and advertising services to: (a) the Government of Russia; or (b) legal persons, entities or bodies established in Russia.
An expansion of the prohibition targeting new investments in the Russian energy sector by prohibiting new investments in the Russian mining sector, with the exception of mining and quarrying activities involving certain critical raw materials.

b) Financial measures:

A new reporting obligation for credit institutions to supply to the national competent authority a list of deposits exceeding 100,000 EUR held by a legal person or entity established outside the EU whose proprietary rights are directly or indirectly owned by more than 50% by Russian nationals or persons residing in Russia.
The addition of the Russian Regional Development Bank to the list of Russian State-owned or controlled entities that are subject to a transaction ban.
An extension of the duration of the exemption from the prohibition to enter into any transactions with certain Russian state-owned entities if such a transaction is strictly necessary for the wind-down of a joint venture or similar legal arrangement.
The possibility for national competent authorities to authorise transactions that are necessary for the divestment of Russian state-owned entities from EU companies.

c) Other sectoral measures:

A ban on EU nationals holding any posts on the governing bodies of Russian State-owned or controlled legal persons or entities established in Russia, with the possibility for competent authorities to grant an authorisation in certain cases.

An extension of the suspension of broadcasting licences in the EU of Russian media outlets and the prohibition on broadcasting their content.

The addition of 141 persons and 49 entities, to the list of persons, entities and bodies subject to restrictive measures.
A new deadline for a derogation allowing divestment by a specific listed entity.
An extension to two newly listed entities of the derogation from the asset freeze and the prohibition to make funds and economic resources available, in order to allow the termination of pre-existing operations, contracts, or other agreements.
A new derogation to unfreeze assets of, and make funds and economic resources available to, certain individuals who held a significant role in the international trade of agricultural and food products (including wheat and fertilisers) prior to their listing, in order to address food security concerns in third countries.

Further information on this new sanctions package is available here and more information on the new listings can be found here.

A summary of the sanctions measures with links to the relevant legal acts will be made available here in due course. Please note that this is a summary overview only. The full legal acts should be consulted in all cases.

Sanctions Adopted on 6 October

On 6 October, the EU adopted its eighth package of economic and individual sanctions in response to Russia’s escalating war in Ukraine and its illegal annexation of Ukraine's Donetsk, Luhansk, Zaporizhzhia and Kherson regions. The Department issued a press release, available here. The new measures were introduced to three existing EU sanctions regimes.

1) The following amendments were made to the existing Donetsk & Luhansk Sanctions Regime under Council Regulation 2022/263:

Amendment of the title of the regime to ‘restrictive measures in response to the illegal recognition, occupation or annexation by the Russian Federation of certain non-government controlled areas of Ukraine’.
An extension of the geographical scope of the restrictions in the regime, to cover all the non-government controlled areas of Ukraine in the oblasts of Donetsk, Kherson, Luhansk and Zaporizhzhia.

2) New measures were introduced to the existing Russia Sectoral Sanctions Regime (Council Regulation 833/2014). These are summarised as follows:

An extension of the list of restricted items which may contribute to Russia's military and technological enhancement or the development of its defence and security sector to include chemical substances, nerve agents and goods that may be used for capital punishment, torture or other cruel, inhuman or degrading treatment or punishment.
A prohibition on the sale, supply, transfer or export of civilian firearms and their essential components and ammunition.
An extension of the import ban on iron and steel products that either originate in Russia or are exported from Russia.
New import restrictions on additional items that generate significant revenues for the Russian Federation, including wood pulp and paper, certain precious stones and metals, cigarettes, plastics and cosmetics, as well as additional items which could contribute to the enhancement of Russian industrial capacities.
Restrictions on the sale, supply transfer or export of additional goods used in the aviation sector.
A prohibition on the provision of maritime transport, and related technical assistance, brokering services or financial, of crude oil and certain petroleum products. A price cap, to be determined at a future date, will allow the provision of transport and these services if the oil or petroleum products are purchased at or below the pre-established price cap.
A ban on EU nationals holding any posts on the governing bodies of certain Russian State-owned or controlled legal persons, entities or bodies.
The addition of the Russian Maritime Register of Shipping to the list of Russian State-owned entities subject to a transaction ban.
The extension of the prohibition on access to EU ports or locks to vessels certified by the Russian Maritime Register of Shipping.
The removal of the threshold for the existing ban on the provision of crypto-asset wallet, account or custody services to Russian persons and residents, thereby banning the provision of such services regardless of the total value of those crypto-assets.
An extension of the existing prohibition on the provision of certain services by banning the provision of architectural and engineering services, as well as IT consultancy services and legal advisory services, to the Government of Russia or legal persons, entities or bodies established in Russia.

3) New measures were also introduced to the existing sanctions regime in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine (Council Regulation 269/2014). These are as follows:

An EU travel ban and asset freeze is applied to an additional 30 individuals, manyinvolved in the organisation of the illegal sham referendums held in in parts of the Donetsk, Kherson, Luhansk, and Zaporizhzhia regions of Ukraine, and their illegal annexation. An asset freeze is also applied to an additional 7 entities.
The introduction of a new listing criterion to sanction those who facilitate the prohibition against circumvention of EU sanctions.
The introduction of further technical derogations from the sanctions.

Further information on this new sanctions package is available here and more information on the new listings can be found here.

Sanctions Adopted on 21 July

On 21 July, the EU adopted a “maintenance and alignment” sanctions package, with the aim of better aligning EU measures with those of G7 partners, closing existing loopholes and tackling circumvention.

The following new measures are imposed under the existing Russia Sectoral Sanctions Regime (Council Regulation 833/2014):

A new prohibition to purchase, import, or transfer gold (including jewellery) if it originates in Russia and it has been exported from Russia into the EU or to any third country after.
An expansion of the list of controlled export items, notably items that may contribute to Russia’s military and technological enhancement or the development of its defence and security sector.
An extension of the existing port access ban to locks to avoid the circumvention of sanctions.
An expansion of 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. The acceptance of deposits for non-prohibited cross-border trade will be subject to a prior authorisation by the national competent authorities.
An extension of the exemption from the prohibition to engage in transactions with certain state-owned entities as regards transactions for agricultural products and the transport of oil to third countries. This measure aims to avoid any potential negative consequences for food and energy security around the world.
Clarifications of existing measures, notably in the fields of public procurement, aviation standards and access to justice.

New measures were also introduced under the Ukraine (Territorial Integrity) Sanctions Regime (Council Regulation 269/2014). These are as follows:

The listings of an additional 54 individuals and 10 entities, including senior members of the political or cultural establishment such as members of the State and provincial Dumas and the Mayor of Moscow, high-ranking military leaders and staff, politicians appointed in Ukrainian territories invaded by Russia, propagandists and leading businesspersons. The sanctioned entities include Sberbank and companies operating in the military sector or the shipbuilding industry.
An obligation for 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. Failure to respect this obligation constitutes a circumvention of the freezing of assets and is subject to penalties.
Further derogations from the asset freeze and the prohibition on making funds or economic resources available to designated persons and entities in order to: (i) urgently prevent or mitigate an event likely to have a serious and significant impact on human health and safety or the environment; (ii) avoid disruptions in the payment channels for agricultural products; (iii) facilitate the orderly wind-down of operations, including correspondent banking relations, with one designated bank (Sberbank).

Further information on this new sanctions package is available here and more information on the new listings can be found here.