Information on sanctions in respect of the situation in Ukraine

The targeted restrictive measures (sanctions) adopted in response to Russia’s actions in Ukraine, since its invasion in February 2022, are the most expansive and hard-hitting sanctions in EU history. Over 2,000 individuals and entities are now subject to EU restrictive measures. Since February 2022 in excess of €300 billion in assets have been frozen across the EU, including approximately €1.8 billion held in Irish credit and financial institutions. An unprecedented range of sectoral measures against Russia have also been adopted.

With a view to limiting Russia’s ability to wage its illegal war in Ukraine and access battlefield goods and technology, these sanctions include measures targeting the financial, energy, technology, defence, media and transport sectors. EU restrictive measures are legally binding on all natural and legal persons in Ireland and the EU.

Sanctions are implemented in EU Regulations, which are directly applicable in all Member States. In order to criminalise any breach of the Regulations as a matter of Irish law, statutory instruments are made which provide that any person who contravenes certain provisions of a regulation will be guilty of an offence and liable to prosecution.

There are a range of additional resources that can be consulted for further details:

• The EU website has a comprehensive overview of measures in place here.

• The EU Sanctions Map has detailed information on all EU sanctions regimes, as well as links to the EU legal acts for each Regime.

• A consolidated list of persons, groups and entities subject to EU financial sanctions is available via this page.

• The EU has also prepared FAQ guidance here.

On 24 June 2024, the EU adopted a fourteenth package of sanctions against Russia, which further strengthened the EU’s efforts to combat circumvention and included new provisions relating to Russia’s energy, financial and transport sectors and included additional anti-circumvention measures.

The full legal text of the Regulation can be accessed here. New elements of the fourteenth package are summarised below:

1) Trade Measures

• Further export bans on goods contributing to the enhancement of Russian industrial capabilities e.g. chemicals, including manganese ores and compounds of rare-earths, plastics, excavating machinery, monitors and electrical equipment.

• New import ban on Russian helium.

• Extended the Common High Priority (CHP) list to include five HS codes concerning computer numerical control (CNC) machine tools used for weapons production.

• New import and export bans on stolen Ukrainian cultural property goods.

• Further measures to fine tune the import ban on Russian diamonds introduced in the 12th package.

• Stricter restrictions for the export of dual-use and advanced technology items to 61 entities – established in Russia and in third countries.

• New prohibitions on accepting applications for registrations in the EU of certain intellectual property rights by Russian nationals and companies.

• The addition of Liechtenstein as a partner country in Annex VIII.

2) Financial Measures

• New prohibition on use of the ‘System for Transfer of Financial Messages’ (SPFS) developed by the Central Bank of Russia or equivalent specialised messaging services set up by the Central Bank of Russia.

• Prohibition on transactions with listed entities using SPFS outside of Russia.

• Prohibition on engaging in transactions with listed credit or financial institution or entity providing crypto assets services outside the EU involved in transactions that facilitate the export, sale, supply, transfer or transport to Russia of dual-use goods and technology, sensitive items, battlefield goods, firearms and ammunition.

3) Transport Measures

• New measure targeting 27 specific vessels contributing to Russia’s aggression against Ukraine, which are subject to a port access ban and ban on provision of services.

• Widening of the prohibition to land in, take off from or overfly the territory of the EU to any aircraft used for a non-scheduled flight, and where a Russian natural or legal person, entity or body, is in a position to effectively determine the place or time for its take-off or landing.

• New obligation for operators to provide any information requested by national competent authorities about non-scheduled flights, including ownership of the aircraft and possibly passengers

• Broadening of the prohibition on the transport of goods by road within the territory of the EU, including in transit, to cover EU operators owned 25% or more by a Russian national or legal person.

4) Energy Measures

• New prohibition on reloading services of Russian LNG in EU territory for the purpose of transshipment operations to third countries. This covers both ship-to-ship transfers and ship-to-shore transfers, as well as re-loading operations, and does not affect import but only re-export to third countries via the EU.

• New prohibition on new investments, as well as the provision of goods, technology and services for the completion of LNG projects under construction.

• New import ban on Russian LNG into specific terminals which are not connected to the EU gas pipeline network.

5) Anti-Circumvention Measures

• Requirement for EU parent companies to undertake their best efforts to ensure that their third-country subsidiaries do not take part in any activities resulting in an outcome that the sanctions seek to prevent.

• Requirement for EU operators selling battlefield goods to third countries to implement due diligence mechanisms capable of identifying and assessing risks of re-exportation to Russia, and mitigating them.

• Requirement for EU operators transferring industrial know-how for the production of battlefield goods to third-country commercial counterparts will now have to include contractual provisions to ensure that such know-how will not be used for goods intended for Russia.

6) Other Measures

• Measures to allow EU operators to claim compensation for damages caused by Russian companies due to sanctions implementation and expropriation.

• New prohibition on political parties and foundations, non-governmental organisations, including think tanks, or media service providers in the EU, accepting funding coming from the Russian state and its proxies. In line with the Charter of Fundamental Rights, the measures will not prevent media service providers and their staff from carrying out other activities in the EU, such as research and interviews.

7) Listings under Council Regulation 269/2014

• Listing of 116 additional individuals and entities (69 individuals and 47 entities) responsible for actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, to be subject to travel bans and asset freezes.

The Commission’s FAQs on this package are available here.

On 23 February 2024, two years after the full-scale invasion and war of aggression against Ukraine, the EU adopted a thirteenth package of sanctions against Russia.

The new elements of the thirteenth package are summarised below:

1) Listings under Council Regulation 269/2014

• Listing of on additional 106 individuals and 88 entities responsible for actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, to be subject to travel bans and asset freezes.

• The new listings agreed in this package target primarily the military and defence sectors and associated individuals, including those involved in DPRK armament supply to Russia, as well as members of the judiciary, local politicians and people responsible for the illegal deportation and military re-education of Ukrainian children.

2) Trade Measures

• Further export bans on goods contributing to the enhancement of Russian industrial capabilities such as electrical transforms.

• Addition of 27 new entities to the list of entities directly supporting Russia’s military and industrial complex in its war of aggression against Ukraine, including entities located in third countries.

• Expansion of the list of restricted items that could contribute to the technological enhancement of Russia’s defence and security sector by adding components for the development and production of unmanned aerial vehicles (UAV).

• The addition of the United Kingdom as a partner country in Annex VIII.

On 18 December 2023, the EU adopted a twelfth package of sanctions against Russia, which included further measures to strengthen the implementation of sanctions and target circumvention. The new elements of the twelfth package are summarised below:

1) Trade Measures

• An import ban on Russian diamonds: restrictions on non-industrial diamonds, mined, processed, or produced, in Russia, as part of an internationally coordinated G7 diamond ban.

• An import ban on raw materials for steel production, processed aluminium products and other metal goods.

• New export controls on dual use/advanced technology goods, including chemicals, thermostats, DC motors and servomotors for unmanned aerial vehicles (UAV), machine tools and machinery parts.

• New export bans on EU industrial goods, including machinery and parts, construction-related goods, processed steel, copper and aluminium goods, lasers, and batteries.

• The addition of 29 Russian and third country entities to the list of entities associated to Russia's military-industrial complex.

2) Energy Measures

• Oil price cap: new measures to more closely monitor the sale of tankers to third countries, as well as require more detailed attestation requirements.

• New import ban on liquified petroleum gas (LPG).

3) Anti-circumvention Measures

• Broadening of the scope of the transit prohibition through Russia by adding certain economically critical goods when these are intended for export to third countries.

• Obligation for operators to contractually prohibit the re-export of certain categories of sensitive goods to Russia, including goods related to aviation, jet fuel, firearms and goods on the common high priority list (“No Russia Clause”).

• Introduction of a new measure that will require the notification of certain transfers of funds out of the EU from EU entities directly or indirectly owned by more than 40% by Russians or entities established in Russia.

4) Listings under Council Regulation 269/2014

• New listing criterion to include persons who benefit from the forced transfer of ownership or control over Russian subsidiaries of EU companies.

• Possibility to keep deceased persons on the asset freeze list.

• Listing of 61 new individuals and 86 new entities subject to travel bans and asset freezes.

The Commission’s FAQs on this package are available here.

On 23 June 2023, the EU adopted its eleventh package of economic and individual restrictive measures to strengthen the existing sanctions and crack down on their circumvention. New elements of the eleventh package are summarised below:

1) Trade Measures

• An extension of the prohibition on the transit via the territory of Russia of sensitive goods and technology which may contribute to Russia’s military and technological enhancement or to the development of the defence or security sector, goods and technology suited for use in aviation or space industry and jet fuel and fuel additives, exported from the EU to third countries.

• Tightening of restrictions on imports of iron and steel goods by requiring importers of sanctioned iron and steel goods that have been processed in a third country to prove that the inputs used do not come from Russia.

• Prohibition to sell, license, transfer or refer intellectual property rights and trade secrets used in connection with restricted goods to prevent the sanctioned goods from simply being manufactured outside the EU.

• An extension of the ban on export of luxury cars to all new and second-hand cars above a certain engine size (> 1.900 cm³), and all electric and hybrid vehicles.

• Addition of 87 new entities to the list of those directly supporting Russia's military and industrial complex in its war of aggression against Ukraine, subject to tighter export restrictions for dual-use and advanced technology items.

• The addition of Switzerland as a partner country in Annex VIII.

2) Transport Measures

• A full ban on trucks with Russian trailers and semi-trailers from transporting goods to the EU.

• Prohibition to access EU ports for;

- vessels that engage in ship-to-ship transfers suspected to be in breach of the Russian oil import ban or G7 Coalition price cap;

- any vessel which does not notify the competent authority at least 48 hours in advance about a ship-to-ship transfer occurring within the Exclusive Economic Zone of a Member State or within 12 nautical miles from the baseline of that Member State's coast;

- vessels which manipulate or turn off their navigation tracking system when transporting Russian oil subject to the oil import ban or G7 price cap.

3) Media ban

• Extension of the media ban to 5 additional media channels.

4) Listings under Council Regulation 269/2014

• The addition of 104 individuals and entities, to the sanctions list.

• Revision of the listing criterion for individuals/entities engaged in circumventing EU sanctions, including those significantly frustrating EU sanctions.

• The addition of a new listing criterion to allow the designation of persons and entities operating in the Russian IT sector with a license from Federal Security Service of the Russian Federation (FSB) or the Russian Ministry of Industry and Trade.

The Commission’s FAQs on this package are available here.

On 25 February 2023, the EU adopted a tenth package of sanctions on Russia’s war of aggression against Ukraine. The measures adopted as part of that package are summarised below:

1) Trade Measures

• New export bans on sensitive dual-use and advanced technologies that contribute to Russia's military capabilities and technological enhancement.

• The listing of 96 additional entities associated to Russia's military-industrial complex subject to tighter export restrictions for dual-use and advanced technology items.

• New export bans on goods that can be easily redirected to be used to support Russia’s war effort, including vehicles, goods easily directed to the Russian military: including electric generators, binoculars, radars, compass, etc., construction goods, goods that are critical for the functioning and enhancement of Russian industrial capacity (electronics, machine parts, pumps, machinery for working metals, etc.), and goods used in the aviation industry.

• New import bans on bitumen and related materials like asphalt, on synthetic rubber and on carbon blacks.

• New ban on Russian nationals serving on governing bodies of Member States' critical infrastructure companies.

• New ban on Russian nationals and entities booking gas storage capacity in the Union (LNG excluded).

2) Media ban

• Extension of the media ban to 2 additional media channels.

3) Anti-circumvention Measures

• New reporting obligations on Russian Central Bank assets.

• New reporting obligations on frozen assets (including for dealings before listings) and assets which should be frozen.

• New notification obligation for private flights between the EU and Russia, directly or via third countries.

• New prohibition to transit dual use goods and firearms via the territory of Russia to third countries

4) Listings under Council Regulation 269/2014

• The addition of 120 individuals and entities to the sanctions list, including Russian decision-makers, senior government officials and military leaders complicit in the war against Ukraine, as well as proxy authorities installed by Russia in the occupied territories in Ukriane, key figures involved in the kidnapping of Ukrainian children to Russia, as well as organisations and individuals, who are polluting the public space with disinformation, adding to the military warfare through information warfare. Other individuals listed include those in Iran involved in the elaboration of drones and components supporting Russia's military. In addition, members and supporters of Russia's Wagner mercenary group and its activities in other countries, such as Mali or Central African Republic, have also been targeted.

• Three Russian banks have been added to the list of entities subject to the asset freeze and the prohibition to make funds and economic resources available.

The Commission’s FAQs on this package are available here.

On 16 December 2023, the EU adopted a ninth package of hard-hitting sanctions against Russia for its aggression against Ukraine, following a full EU import ban on Russian seaborne crude oil, and of the global oil price cap agreed with G7 partners. The measures adopted as part of that package are summarised below:

1) Trade Measures

• New export bans on sensitive dual-use and advanced technologies that contribute to Russia's military capabilities and technological enhancement. This includes drone engines, camouflage gear, additional chemical/biological equipment, riot control agents and additional electronic components found in Russian military systems on the battlefield.

• The listing of 168 additional Russian organisations closely linked to the Russian military-industrial complex.

• New bans on market research and public opinion polling services, technical testing and analysis services, and advertising services.

• New ban on the direct exports of drone engines to Russia and the export to any third countries, where there is a suspicion that they will be used in Russia is now restricted.

2) Media ban

• Extension of the media ban to 4 additional media channels.

3) Listings under Council Regulation 269/2014

• The addition of almost 200 additional individuals and organisations to the sanctions list, including the Russian armed forces, as well as individual officers and defence industry companies, members of the State Duma and Federation Council, ministers, Russian proxy authorities in occupied areas of Ukraine and political parties, and key figures involved in in Russia's brutal and deliberate missile strikes against civilians, in the kidnapping and abduction to Russia of Ukrainian children, and in the theft of Ukrainian agricultural products.

• Three Russian banks have been added to the list.

The Commission’s FAQs on this package are available here.

On 5 October 2023, the EU adopted an eighth package of hard-hitting sanctions against Russia. The measures adopted as part of that package are summarised below:

1) Trade Measures

• New export bans on coal including coking coal, specific electronic components (found in Russian weapons), technical items used in the aviation sector, and certain chemicals.

• New ban on exporting small arms and other goods under the anti-torture Regulation.

• New import ban on 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.

• Widening of the ban on the provision of services to the government of Russia or legal persons established in Russia: these now include IT consultancy, legal advisory, architecture and engineering services.

• New ban on EU nationals holding posts in the governing bodies of certain state-owned enterprises.

2) Financial Measures

• Extension of the existing prohibitions on crypto assets to include a ban on all crypto-asset wallets, accounts, or custody services, irrespective of the amount of the wallet (previously up to €10,000 was allowed).

• New ban on all transactions with the Russian Maritime Register, adding it to the list of state-owned enterprises that are subject to a transaction ban.

3) Energy Measures

• Oil price cap: This package marks the beginning of the implementation within the EU of the G7 agreement on Russian oil exports. While the EU's ban on importing Russian seaborne crude oil remains fully in place, the price cap, once implemented, would allow European operators to carry out and support the transport of Russian oil to non-EU countries, provided its price remains under a pre-set “cap”. The measure took effect from 5 December 2022 for crude and 5 February 2023 for refined petroleum products.

4) Listings under Council Regulation 269/2014

• Additional individuals and entities are subject to sanctions, including those involved in Russia's occupation, illegal annexation, and sham “referenda” in the occupied territories/oblasts of Donetsk, Luhansk, Kherson, and Zaporizhzhia regions. The list also includes individuals and entities working in the defence sector, as well as companies supporting the Russian armed forces.

• New listing criterion, which will allow it to sanction individuals who facilitate infringements of the prohibition against circumvention of sanctions.

The Commission’s FAQs on this package are available here.

On 21 July 2022, the EU adopted a “maintenance and alignment” seventh package to strengthen legal certainty for operators and enforcement by Member States and align the EU’s sanctions with those of its allies and partners. The measures adopted as part of that package are summarised below:

1) Trade Measures

• New import ban on gold originating from Russia and exported from Russia into the EU or to any non-EU country.

• New additions to the list of goods suited for use in oil refining and liquefaction of natural gas, whose export is prohibited.

• New exemptions for certain export prohibitions for medical and pharmaceutical purposes.

• New exemptions for agricultural products and the transport of oil to non-EU countries with certain state-owned organisations.

2) Transport Measures

• Port access ban: Russian flagged vessels are banned from accessing locks to prevent the circumvention of sanctions

3) Listings under Council Regulation 269/2014

• Addition of a further 54 individuals and 10 organisations on the sanctions list.

The Commission’s FAQs on this package are available here.

On 03 June 2022, the EU adopted a sixth package of sanctions against Russia. The measures adopted as part of that package are summarised below:

1) Trade Measures

• New import ban on crude oil and petroleum products originating in Russia.

• New additions to the list of goods and technology which may contribute to the technological enhancement of Russia’s defence and security sector and whose export is prohibited. This includes 80 chemicals which can be used to produce chemical weapons.

• New additions to the list of military-affiliated end-user entities in Russia and Belarus subject to tighter export restrictions.

2) Financial Measures

• New ban on providing accounting; auditing; tax consulting; management consulting; and public relations services to entities established in Russia.

• The exclusion of additional Russian and Belarusian financial institutions from the SWIFT payments system.

3) Transport Measures

• New ban on EU operators insuring and financing the transport, in particular through maritime routes, of oil to non-EU countries.

4) Media ban

• Extension of the media ban to 3 additional media channels.

The Commission’s FAQs on this package are available here.

On 08 April 2022, the EU adopted a fifth package of sanctions against Russia. The measures adopted as part of that package are summarised below:

1) Trade Measures

• New import ban on all forms of coal.

• Further targeted export bans that include, in particular, quantum computing, advanced semiconductors, sensitive machinery, transportation and chemicals.

• Additional import bans including cement, rubber products, wood, spirits (including vodka), liquor, high-end seafood (including caviar), and an anti-circumvention measure against potash imports from Belarus.

• New ban on the participation of Russian nationals and organisations in procurement contracts in the EU.

2) Financial Measures

• New ban on the provision of financial and non-financial support to Russian publicly owned or controlled organisations under EU, Euratom and Member State programmes.

• New ban on providing high-value crypto-asset services to Russia.

• New ban on providing trust services to Russia.

• New transaction ban and asset freeze on four additional Russian banks.

• Extension of the export ban on banknotes and the ban on the sale of transferrable securities to Russian nationals or organisations to all official EU currencies.

3) Transport Measures

• New ban on Russian and Belarusian freight road operators working in the EU. Certain exemptions cover essentials, such as mail, agricultural and food products, humanitarian aid as well as energy.

• New entry ban on Russian-flagged vessels to EU ports. Exemptions apply for medical, food, energy, and humanitarian purposes, amongst others

4) Listings under Council Regulation 269/2014

• Addition of a further 217 individuals and 18 organisations to the sanctions list.

The Commission’s FAQs on this package are available here.

On 15 March 2022, the EU adopted a fourth package of sanctions against Russia in response to its aggression against Ukraine. The measures adopted as part of that package are summarised below:

1) Trade Measures

• New import ban on iron and steel products, as listed in the Regulation, which originate in Russia, or which have been exported from Russia.

• New export ban on luxury goods.

• New ban on transactions with certain Russian State-owned enterprises, with the exception of State-owned banks, railways and the maritime shipping register.

• New ban on investments in the Russian energy sector, with the exception of nuclear energy and the transport of energy products.

• New ban on EU agencies providing financial rating services to Russian companies.

2) Financial Measures

• New ban on transactions with certain Russian State-owned enterprises, with the exception of State-owned banks, railways and the maritime shipping register.

• New ban on investments in the Russian energy sector, with the exception of nuclear energy and the transport of energy products.

• New ban on EU agencies providing financial rating services to Russian companies.

3) Listings under Council Regulation 269/2014

• Addition of a further 15 individuals and 9 organisations to the sanctions list, including include oligarchs and business elites linked to the Kremlin, as well as companies active in military and defence sectors, and disinformation.

The Commission’s FAQs on this package are available here.

On 09 March 2022, the EU adopted further targeted sanctions in view of the situation in Ukraine and in response to Belarus's involvement in the aggression. The measures adopted as part of that package are summarised below:

1) Trade Measures

• Further restrictive measures with regard to the export of maritime navigation goods and radio communication technology to Russia.

2) Financial Measures

• New ban on transactions with the Central Bank of Belarus related to the management of reserves or assets, and the provision of public financing for trade with and investment in Belarus.

• Exclusion of three Belarusian banks from the SWIFT system.

• New ban on the listing and provision of services in relation to shares of Belarus state-owned organisations on EU trading venues as of 12 April 2022.

• New ban on the acceptance of deposits exceeding €100.000 from Belarusian nationals or residents, the holding of accounts of Belarusian clients by the EU central securities depositories, as well as the selling of euro-denominated securities to Belarusian clients.

• New ban on the provision of euro denominated banknotes to Belarus.

3) Listings under Council Regulation 269/2014

• Addition of a further 60 individuals to the sanctions list.

On 02 March 2022, the EU adopted a third package of sanctions in view of the situation in Ukraine and in response to Belarus's involvement in the aggression. The measures adopted as part of that package are summarised below:

1) Trade Measures

• New export ban on dual-use goods and technology to any natural or legal person, entity or body in Belarus or for use in Belarus.

• New export ban on goods and technology which might contribute to Belarus’ military, technological, defence and security enhancement, listed in the Regulation under the categories of electronics; computers; telecommunications and information security; sensors and lasers; navigation and avionics; marine; and aerospace and propulsion, to any natural or legal person, entity or body in Belarus or for use in Belarus.

• New export ban on specific machinery, listed in the Regulation, to Belarus or for use in Belarus.

• New export ban on goods used for the production or manufacturing of tobacco products, listed in the Regulation, to Belarus or for use in Belarus.

• New import ban on mineral products, potassium chloride (“potash”) products, wood products, cement products, iron and steel products and rubber products, as listed in the Regulation, which originate in Belarus or which have been exported from Belarus.

2) Financial Measures

• New ban on transactions with the Russian Central Bank.

• New ban on investing in projects co-financed by the Russian Direct Investment Fund.

• New ban on the the provision of euro-denominated banknotes to Russia.

• Exclusion of key Russian banks from the SWIFT system.

3) Transport Measures

• New ban on the overflight of EU airspace and on access to EU airports by Russian carriers of all kinds.

4) Media Ban

• New ban on state-owned media Russia Today and Sputnik broadcasting in the EU.

5) Listings under Council Regulation 269/2014

• Addition of 46 individuals and 1 organisation, including 22 members of the Belarusian military personnel, to the sanctions list.

On 25 February 2022, the EU adopted a second package of sanctions in view of Russia’s military aggression against Ukraine. The measures adopted as part of that package are summarised below:

1) Trade Measures

• New export ban on dual-use goods and technology, to Russia or for use in Russia.

• New export ban on specific goods and technology which might contribute to Russia’s military, technological, defence and security enhancement, listed in the Regulation under the categories of electronics; computers; telecommunications and information security; sensors and lasers; navigation and avionics; marine; and aerospace and propulsion, to Russia or for use in Russia.

• New export ban on goods and technology, listed in the Regulation, suited for use in oil refining, to Russia or for use in Russia.

• New export ban on specific goods and technology, listed in the Regulation, suited for use in aviation or space industry, to Russia or for use in Russia.

• New ban on the sale of all aircraft, spare parts and equipment to Russian airlines.

2) Listings under Council Regulation 269/2014

• New Visa policy sanctions, on 99 additional individuals, that mean Russian diplomats and related groups, and business people will no longer have privileged access to the EU.

In response to Russia recognising the non-government controlled areas of the Donetsk and Luhansk oblasts of Ukraine and its decision to send troops into the region, the Council adopted a package of sanctions on 23 February 2022. These sanctions target:

• the ability of the Russian state and government to access the EU’s capital and financial markets and services, to limit the financing of escalatory and aggressive policies;

• economic relations between the two non-government controlled regions and the EU, to ensure that those responsible clearly feel the economic consequences of their illegal and aggressive actions;

• individuals and organisations who played a role in undermining or threatening the territorial integrity and independence of Ukraine. With these additions, the list comprises a total of 555 individuals and 52 organisations.