Foilsiú
EU trade sanctions in response to situation in Ukraine
Ó An Roinn Fiontar, Trádála agus Fostaíochta
Foilsithe
An t-eolas is déanaí
Teanga: Níl leagan Gaeilge den mhír seo ar fáil.
- 1. Trade sanctions adopted on 16 December 2024
- 2. Trade sanctions adopted on 24 June 2024
- 3. Trade sanctions adopted on 23 February 2024
- 4. Trade sanctions adopted on 18 December 2023
- 5. Trade sanctions adopted on 23 June 2023
- 6. Trade sanctions adopted on 24 February 2023
- 7. Aircraft retained in Russia against the will of their non-Russian owner
- 8. Divestment from Russia or the wind-down of business activities in Russia
- 9. Trade sanctions adopted on 16 December 2022
- 10. Trade sanctions adopted on 6 October 2022
- 11. Trade sanctions adopted on 21 July 2022
- 12. Importation of goods using Russian-flagged vessels
- 13. Trade sanctions adopted on 3 June 2022
- 14. Trade sanctions adopted on 8 April 2022
- 15. Trade sanctions adopted on 15 March 2022
- 16. Trade sanctions adopted on 9 March 2022
- 17. Trade sanctions adopted on 2 March 2022
- 18. Trade sanctions adopted on 25 February 2022
- 19. Trade sanctions adopted on 23 February 2022
- 20. Trade sanctions adopted in 2014
- 21. Exemptions
- 22. Further information
On 16 December 2024, the EU adopted additional sanctions in response to Russia’s illegal and unprovoked military aggression against Ukraine. These sanctions build on, and expand, the earlier sanctions.
EU sanctions regulations have direct effect in all member states of the EU and, as such, are legally binding on all natural and legal persons in Ireland. Private companies, therefore, have an obligation to ensure that they are in full compliance with these new measures. A natural or legal person who contravenes a provision of an EU sanctions regulation shall be guilty of an offence and liable to prosecution.
This webpage summarises the key trade provisions of the EU sanctions enacted to date. The information on this page is provided for information purposes only and does not constitute a legal interpretation of the EU regulations. Traders should consult the EU regulations directly, and when necessary, obtain professional advice.
This page will be regularly reviewed, and while every effort has been made to ensure that the information is accurate, the situation is very dynamic and the sanctions, including the lists of prohibited goods, are liable to change.
The major trade-related elements of the 15th package, set out in Council Regulation (EU) 2024/3192 of 16 December 2024 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, are as follows:
Includes 84 listings, consisting of 54 persons and 30 entities responsible for actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine.
Individuals listing includes the military unit responsible for the striking of the Okhmadyt children hospital in Kyiv, senior managers in leading companies in the energy sector, individuals responsible for children deportation, propaganda and circumvention, as well the Minister of Defence and the Deputy Chief of the General Staff of the Democratic People's Republic of Korea.
Entities listings are targeted primarily at Russian defence companies and shipping companies responsible for the transportation of crude oil and oil products by the sea. Also included are a chemical plant and a civil Russian airline which is an important provider of logistical support to the Russian military. For the first time, there are fully-fledged sanctions (travel ban, asset freeze, prohibition to make economic resources available) on various Chinese actors supplying drone components and microelectronic components in support of Russia’s war of aggression against Ukraine.
Further vessels have been added to the list of those subject to a port access ban and ban on provision of a broad range of services related to maritime transport. This measure is intended to target non-EU tankers that are part of Putin’s shadow fleet circumventing the oil price cap mechanism or support the energy sector of Russia, or vessels that are responsible for transporting military equipment for Russia or involved in the transport of stolen Ukrainian grain. 52 vessels originating from third countries have been targeted on these grounds, bringing the total of designated vessels to 79.
A total of 32 new entities have been added to the list of those directly supporting Russia’s military and industrial complex in its war of aggression against Ukraine. They will be subject to tighter export restrictions concerning dual use goods and technologies, as well as goods and technology which might contribute to the technological enhancement of Russia’s defence and security sector. Some of these entities are located in third countries (China, India, Iran, Serbia and the United Arab Emirates) and have been involved in the circumvention of trade restrictions or have engaged in the procurement of sensitive items used for Russian military operations, like UAVs and missiles.
To better protect European companies from litigations with Russian counterparts, there is a prohibition on the recognition or enforcement in the EU of those rulings issued by Russian courts based on Article 248 of the Arbitration Procedure Code of the Russian Federation.
A derogation has been introduced allowing the release of cash balances held by EU central securities depositories (CSDs). This is necessary in light of increasing litigation and retaliatory measures in Russia that result in the seizing of assets of CSDs in the EU.
The EU has extended the deadlines applicable to certain derogations needed for divestments from Russia. The exceptional extension of the divestment derogations is necessary to enable EU operators to exit as swiftly as possible from the Russian market.
The major trade-related elements of the 14th package, set out in Council Implementing Regulation (EU) 2024/1745 of 24 June 2024, amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, are as follows:
I prohibits 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. Bans new investments, and the provision of goods, technology, and services for completing LNG projects under construction, such as Arctic LNG 2 and Murmansk LNG. Introduces import restrictions on Russian LNG through EU terminals not connected to the natural gas system.
II requires EU parent companies to undertake best efforts to ensure third-country subsidiaries do not participate in any activities resulting in an outcome which would undermine sanctions. EU operators selling battlefield goods which are found in Ukraine or are critical to the development of Russian military systems to third countries must implement due diligence mechanisms capable of identifying and assessing risks of re-exportation to Russia. EU operators transferring industrial know-how for the production of battlefield goods to third-country commercial counterparts must include contractual provisions to ensure that this know-how will not be used for goods intended for Russia.
III outlaws the use of the SPFS financial messaging service developed by the Central Bank of Russia to neutralise the effect of restrictive measures. EU entities operating outside of Russia will be forbidden from connecting to the SPFS or equivalent specialised financial messaging services. EU operators will be barred from making transactions with specifically listed entities using SPFS outside of Russia. Introduces a ban on transactions with targeted credit and financial institutions and crypto assets providers established outside of the EU, when these entities facilitate transactions that support Russia’s defence-industrial base through the export, supply, sale, transfer or transport towards Russia of dual-use goods and technology, sensitive items, battlefield goods, firearms and ammunition.
IV prohibits political parties and foundations, non-governmental organisations, including think tanks, or media service providers in the EU, from accepting funding coming from the Russian state and its proxies.
V Imposes a port access ban and ban on provision of services targeting specific vessels supporting Russia’s warfare. These vessels can be designated for various reasons such as the transport of military equipment for Russia, the transport of stolen Ukrainian grain, and support in the development of Russia’s energy sector, for instance through the transport of LNG components or transshipments of LNG. This measure also targets tankers part of Putin’s dark fleet which circumvent the EU and Price Cap Coalition’s caps, while adopting deceptive shipping practices in complete disregard of international standards. Widens the EU flight ban; The prohibition to land in, take off from or overfly the territory of the EU will also apply 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 to reach, for instance, a holiday destination or a business meeting. Furthermore, operators must provide any information requested by member states’ national competent authorities about non-scheduled flights, including ownership of the aircraft and possibly passengers. Expands the prohibition on the transport of goods by road within the territory of the EU, including in transit, so as to cover EU operators which are owned 25% or more by a Russian natural or legal person.
VI adds 61 entities supporting Russia’s military-industrial complex to the list, imposing tighter export restrictions concerning dual use goods and technologies, as well as goods and technology which might contribute to the technological enhancement of Russia’s defence and security sector. Expands the list of restricted items that could contribute to the technological enhancement of Russia’s defence and security sector, adding machine tools and “All Terrain Vehicles.” Introduces further export restrictions on goods enhancing Russian industrial capabilities, such as chemicals, including manganese ores and compounds of rare-earths, plastics, excavating machinery, monitors, and electrical equipment, and further restrictions on import of helium from Russia. Adds Liechtenstein to the list of partner countries applying restrictive measures on iron and steel imports from Russia and a set of import control measures that are substantially equivalent to those of the EU.
VII allows EU operators to claim compensation for damages caused by Russian companies due to sanctions implementation and expropriation. It also creates the instrument to draw up a list of companies subject to a transaction ban for meddling with arbitration and court competence.
VIII imposes restrictions on accepting applications for registrations in the EU of certain intellectual property rights by Russian nationals and companies, Forbids purchase, import, transfer or export Ukrainian cultural property goods and other goods of archaeological, historical, cultural, rare scientific or religious importance, where there are reasonable grounds to suspect that the goods have been unlawfully removed from Ukraine.
The major trade-related elements of the package, set out in Council Regulation (EU) 2024/745 of 23 February 2024, amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, are as follows:
I includes 194 individual designations, bringing the total EU listings to over 2000. These designations target:
- over 140 companies and individuals from Russia's military-industrial complex involved in manufacturing missiles, drones, anti-aircraft missile systems, military vehicles, high-tech components for weapons, and other military equipment
- 10 Russian companies and individuals involved in shipping armaments from the Democratic People's Republic of Korea (DPRK) to Russia, including the DPRK's Defence Minister and several Belarusian entities supporting the Russian armed forces
- a Russian logistics company and its director involved in parallel imports of prohibited goods, and another actor involved in a procurement scheme
- six judges and 10 officials in the occupied territories of Ukraine
- 15 individuals and 2 entities involved in the forced transfer, deportation, and military indoctrination of Ukrainian children, including in Belarus
II deepens actions to prevent Russia from acquiring Western sensitive technologies for its military, specifically targeting drone components. Adding:
- 27 Russian and third-country companies to the list associated with Russia's military-industrial complex, imposing export restrictions on dual-use goods and technology
- 17 Russian companies involved in the development, production, and supply of electronic components used in drones
III adds the United Kingdom to the list of partner countries for iron and steel imports, applying restrictive measures and import control measures equivalent to those in EU Regulation (EU) No 833/2014.
The major trade-related elements of the package, set out in Council Regulation (EU) 2023/2878 of 18 December 2023, amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, are as follows:
I Introduces a No Russia Clause. Exporters are required to contractually prohibit re-exportation to Russia and re-exportation for use in Russia of particularly sensitive goods and technology, when selling, supplying, transferring or exporting to a third country, with the exception of partner countries.
II Bans Russian nationals from owning, controlling or holding any posts on the governing bodies of the legal persons, entities or bodies providing crypto-asset wallet, account or custody services to Russian persons and residents.
III Imposes a prohibition on the direct or indirect import, purchase or transfer of diamonds from Russia. This prohibition applies to diamonds originating in Russia, diamonds exported from Russia, diamonds transiting Russia and Russian diamonds when processed in third countries.
IV Expands the list of restricted items that could contribute to the technological enhancement of Russia’s defence and security sector to include: chemicals, lithium batteries, thermostats, DC motors and servomotors for unmanned aerial vehicles (UAV), machine tools and machinery parts.
V Extends the prohibition on the provision of services to also include the provision of software for the management of enterprises and software for industrial design and manufacture.
VI Introduces further restrictions on imports of goods which generate significant revenues for Russia and thereby enable the continuation of its war of aggression against Ukraine, such pig iron and spiegeleisen, copper wires, aluminium wires, foil, tubes and pipes for a total value of €2.2 billion per year.
VII Introduces an import ban on liquefied propane (LPG) with a 12-month transitional period.
VIII Expands the transit ban that currently applies to dual use goods and technologies exported from the EU to third countries via the territory of Russia to all battlefield goods.
Note: The list of individuals and entities subject to sanctions has been significantly expanded. The Council added 30 new entities to the list of those directly supporting Russia's military and industrial complex in its war of aggression against Ukraine. They will be subject to tighter export restrictions concerning dual use goods and technologies, as well as goods and technology which might contribute to the technological enhancement of Russia's defence and security sector. Some of these 30 entities belong to third countries involved in the circumvention of trade restrictions, or are Russian entities involved in the development, production and supply of electronic components for Russia's military and industrial complex.
The major trade-related elements of the package, set out in Council Regulation (EU) 2023/1214 of 23 June 2023, amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, are as follows:
I Introduces a new anti-circumvention tool. This mechanism enables the EU to restrict the sale, supply, transfer or export of specified sanctioned goods and technology to certain third countries whose jurisdictions are considered to be at continued and particularly high risk of circumvention. This new “anti-circumvention” tool will be an exceptional and last resort measure when other individual measures and outreach by the EU to concerned third countries have been insufficient to prevent circumvention.
II Extension of the transit prohibition for certain sensitive goods (advanced technology, aviation-related materials) exported from the EU to third countries, via Russia.
III Restriction on the exports of further technological items found on the battlefield in Ukraine or equipment needed to produce such items.
IV Tightening 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 provide evidence at the moment of importation, that the inputs used do not come from Russia.
V 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.
VI 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.
VII A full ban on certain types of machinery components.
VIII A full ban on trucks with Russian trailers and semi-trailers from transporting goods to the EU.
IX 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.
X Insertions of strict and very targeted derogations to the existing export bans to enable the maintenance of the CPC (Caspian Pipeline Consortium) pipeline which transports Kazakh oil to the EU through Russia.
XI Insertion of an exemption for the provision of pilot services in specific circumstances.
XII Insertion of a temporary derogation to allow for the provision of prohibited services which are legally required for the divestment of Russian operators from the EU.
Note: The list of individuals and entities subject to sanctions has been significantly expanded. In addition to the Russian and Iranian entities already listed, the listings now also include entities registered in Hong Kong, China, Uzbekistan, the United Arab Emirates, Syria and Armenia. Over 100 additional individuals and entities are subject to asset freezes. These include senior military officials, decision makers on the war, persons involved in the illegal deportation of Ukrainian children to Russia, judges who took politically motivated decisions against Ukrainian citizens, persons responsible for the looting of cultural heritage, businesspersons, propagandists, as well as Russian IT companies providing critical technology and software to the Russian intelligence, banks operating in the occupied territories and entities working with the Russian armed forces. Accordingly, traders should conduct appropriate due diligence, including thorough screening of all parties to a transaction, to avoid inadvertently breaching the sanctions.
The 10th package of EU sanctions came into effect on 26 February 2023. The major trade-related elements of the package, which are set out in 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, are as follows:
I Further extends 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, adding rare-earths and compounds, electronic integrated circuits and thermographic cameras, among others.
II Extends the list of restricted items, the sale, supply, transfer or export of which might contribute to the enhancement of Russia’s industrial capabilities.
III Further extends to the lists of items which generate significant revenues for Russia, whose import is prohibited, to include:
a) Bitumen and related materials such as asphalt, and
b) Synthetic rubber and carbon blacks.
IV Further extends 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.
V Prohibits the transit of dual use goods and firearms via the territory of Russia to third countries.
VI Introduces a prohibition on Russian nationals from serving on governing bodies of Member States' critical infrastructure companies, as specified.
VII Introduces a prohibition on providing gas storage capacity in the Union to Russian nationals, natural persons residing in Russia or legal persons or entities established in Russia.
VIII Introduces a derogation, which is temporary and limited in scope, from the prohibition on providing certain services set out in the Regulation, in order to further facilitate an expeditious exit from the Russian market.
IX Introduces an exemption from the prohibition on the provision of pilot services, for reasons of maritime safety, to vessels in innocent passage.
Note: The list of individuals and entities subject to sanctions has been significantly expanded. This now includes seven Iranian entities manufacturing goods which have been used by Russia’s military in its war of aggression. Therefore, traders should carry out appropriate due diligence, including thorough screening of all parties to a transaction, to avoid inadvertently breaching the sanctions.
On 21 December 2022 the European Commission published guidance on the execution of insurance settlements in relation to aircraft retained in Russia against the will of their non-Russian owner.
Under Article 3c of Council Regulation (EU) 833/2014 it is prohibited to sell, supply, transfer or export, directly or indirectly, aircraft, whether or not originating in the Union, to any natural or legal person, entity or body in Russia or for use in Russia.
However, the Commission’s guidance clarifies that, in circumstances where aircraft are retained in Russia against the will of their non-Russian owner, it is not prohibited under this Article for the non-Russian owner of the aircraft to execute an insurance settlement with a Russian entity leading to the payment of the market value of the lost aircraft by the latter, provided that five specific conditions are satisfied.
The full guidance, and the specific conditions necessary for the execution of the settlement, are set out in Section 12.4 of frequently asked questions concerning sanctions adopted following Russia’s military aggression against Ukraine and Belarus' involvement in it.
Article 12b of Council Regulation (EU) 833/2014, which was introduced in the 9th EU sanctions package on 16 December, provides for a temporary derogation from the prohibition on the sale, supply and transfer of certain goods, when such a transaction is necessary for the divestment from Russia or the wind-down of business activities in Russia.
This derogation is designed to facilitate EU entities with subsidiaries or other investments in Russia to disengage from the Russia economy. The derogation can only be authorised by a Competent Authority if certain conditions are satisfied, including most particularly, that the goods cannot be used for a military purpose in Russia. This Article is not applicable in the context of aircraft that have been retained in Russia against the will of their non-Russian owner.
The 9th package of EU sanctions came into effect on 17 December 2022. The major trade-related elements of the package, which are set out in 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, are as follows:
I Extends 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.
II Extends 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. This prohibition as well as the prohibition to land, take off from, or overfly the territory of the Union applies to both manned and unmanned aircrafts.
III Introduces a derogation to allow the provision of technical assistance related to the use of goods and technology suited for use in aviation or the space industry when this is necessary to avoid collision between satellites, or their unintended re-entry into the atmosphere.
IV Extends 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.
V Introduces a derogation, which is temporary and limited in scope, from the import and export prohibitions in the Regulations, in order to facilitate an expeditious exit from the Russian market.
VI Extends the existing prohibition on the provision of certain services to Russia to include the provision of:
a) advertising, market research and public opinion polling services, and
b) product testing and technical inspection services.
Note: The provision of technical assistance related to goods exported to Russia remains allowed, provided that the sale, supply, transfer or export of such goods is not prohibited under this Regulation at the time at which such technical assistance is provided.
Note: The list of entities connected with Russia’s military and industrial complex has been significantly expanded. Therefore, traders should carry out appropriate due diligence, including thorough screening of all parties to a transaction, to avoid inadvertently breaching the sanctions.
The 8th package of EU sanctions came into effect on 7 October 2022. The major trade-related elements of the package, which are set out in 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, are as follows:
I Extends the prohibition on the provision of services to Russia to include the provision of:
a) architectural and engineering services, including integrated engineering services, urban planning and landscape architectural services and engineering related scientific and technical consulting services,
b) IT consultancy services, covering the installation of computer hardware and software implementation services, including assistance services to the clients in the installation of computer hardware and computer networks, and all consultancy services involving development and implementation of software, and
c) legal advisory services.
II Prohibition on the sale, supply, transfer or export of firearms, their parts and essential components and ammunition.
III Further extends the import ban on coal and other products that either originate in Russia or have been exported from Russia.
IV Further extends the import ban on iron and steel products that either originate in Russia or have been exported from Russia.
V Additions to the lists of items which generate significant revenues for Russia, whose import is prohibited, including:
a) wood pulp and paper,
b) certain stones and precious metals used in the jewellery industry,
c) certain machinery and chemical items,
d) cigarettes,
e) plastics and finished chemical products such as cosmetics.
VI Additions to the list of goods which could contribute to the enhancement of Russian industrial capacities, whose export is prohibited.
VII Additions to the list of goods which could contribute to Russia’s military and technological enhancement, whose export is prohibited.
VIII Additions to the list of goods used in the aviation sector, whosesale, supply transfer or export is prohibited.
IX Prohibits the maritime transport, including through ship-to-ship transfers, of certain crude oil and certain petroleum products which originate in Russia, or which have been exported from Russia, to third countries.
X Introduction of an exemption from the prohibition on the maritime transport by vessel to third countries of crude oil or petroleum products which originate in or are exported from Russia, and on the provision of technical assistance, brokering services or financing or financial assistance related to these products, where they have been purchased at or below a pre-established price cap set by the Price Cap Setting Body of the G7+ Price Cap Coalition.
XI The ban on Russian-flagged vessels accessing EU ports and locks now also applies to vessels certified by the Russian Maritime Register of Shipping.
XII A ban on EU nationals to hold any posts on the governing bodies of certain listed state-owned or controlled entities or bodies.
Additionally, Council Regulation (EU) 2022/263 as amended, which includes provisions restricting certain trading activities, both import and export, has been extended to include the four regions illegally annexed by Russia, the non-government controlled areas of Ukraine in the oblasts of Donetsk, Kherson, Luhansk and Zaporizhzhia.
Note: 1,435 Russian and 230 Belarusian legal persons, entities and bodies, are currently subject to financial sanctions. Therefore, traders should carry out appropriate due diligence, including thorough screening of all parties to a transaction, to avoid inadvertently breaching the sanctions.
The “maintenance and alignment” package of EU sanctions came into effect on 22 July 2022 and the major trade-related elements of the package, which are set out in Council Regulation (EU) 2022/1269, amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, are as follows:
I A ban on the purchase, import, or transfer of gold, including jewellery, if it originates in Russia.
II Additions to the lists of goods that may contribute to Russia’s military and technological enhancement, or the development of its defence and security sector, whose export is prohibited.
III Additions to the list of goods suited for use in oil refining and liquefaction of natural gas, whose export is prohibited.
IV The exemption from the prohibition on exports of ‘Dual-use’ and Advanced Technology items intended for cyber-security and information security applications has been removed. However, A National Competent Authority (the department) may authorise a derogation for such exports.
V A National Competent Authority may authorise a derogation from the prohibition on the export of goods that could contribute to the enhancement of Russian industrial capacities, for medical, pharmaceutical or humanitarian purposes.
VI The ban on Russian-flagged vessels accessing EU ports now applies to EU locks as well.
VII Additions to the list of military-affiliated end-user entities in Russia subject to tighter export restrictions.
VIII Additions to the lists of Russian individuals and entities subject to financial sanctions.
Note: 1,320 Russian and 230 Belarusian legal persons, entities and bodies, are currently subject to financial sanctions. Therefore, traders should carry out appropriate due diligence, including thorough screening of all parties to a transaction, to avoid inadvertently breaching the sanctions.
From 16 April 2022 EU sanctions prohibit vessels registered under the flag of Russia from accessing EU ports. This also applies to vessels that have re-registered from the flag of Russia to the flag of another state after 24 February 2022.
The EU sanctions, make provision for a national Competent Authority (Department of Enterprise, Trade and Employment) to authorise a derogation from the prohibition on limited and very specific grounds. A derogation however, if authorised, would only permit the vessel to access an Irish port. It would be without prejudice to other sanctions measures that may prohibit or restrict the importation of the goods on the vessel. Furthermore, a derogation would only be considered when an importer has demonstrated that there is no feasible alternative at this time to making use of a vessel registered under the flag of Russia.
Under Article 3ea(5) of EU Regulation 833/2014 as amended, the Competent Authority may allow a derogation for a sanctioned vessel to access a port after having determined that the access is necessary for:
- the purchase, import or transport of natural gas, oil, including refined petroleum products, as well as titanium, aluminium, copper, nickel, palladium and iron ore, as well as certain chemical and iron products as listed in Annex XXIV to the Regulation
- purchase, import or transport of pharmaceutical and medical products, agricultural and food products, including wheat and fertilisers whose import, purchase and transport is permitted under the Regulation
- humanitarian purposes
- transport of nuclear fuel and other goods strictly necessary for the functioning of civil nuclear capabilities
Importers seeking a derogation on one of these grounds should complete the Derogation Application Form below and submit it electronically to the relevant government department:
| Department | |
| Department of Agriculture, Food and the Marine | feedimports@agriculture.gov.ie |
| Department of the Environment, Climate and Communications | energyimports@decc.gov.ie |
| Department of Health | medicines_unit@health.gov.ie |
The 6th package of EU sanctions came into effect on 4 June 2022 and the major trade-related elements of the package, which are set out in Council Regulation (EU) 2022/879, amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, are as follows:
I A ban on the importation of crude oil and petroleum products originating in Russia.
II An expansion of 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.
III An expansion of the list of items that generate significant revenues for Russia whose import into the EU is prohibited.
IV An expansion of the list of military-affiliated end-user entities in Russia and Belarus subject to tighter export restrictions.
V A ban on providing accounting; auditing; tax consulting; management consulting; and public relations services to entities established in Russia.
VI The exclusion of additional Russian and Belarusian financial institutions from the SWIFT payments system.
VII Further additions to the lists of Russian and Belarusian individuals and entities subject to financial sanctions.
Note: 1,186 Russian and 130 Belarusian individuals and entities are currently subject to financial sanctions. Therefore, traders should carry out thorough due diligence on all parties to a transaction to avoid inadvertently breaching the sanctions.
These sanctions came into effect on 9 April 2022 and the trade provisions, which are set out in Council Regulation (EU) 2022/576, amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, are as follows:
I An expansion of the categories of iron and steel products subject to an import ban.
II An expansion of the categories of luxury goods, subject to an export ban.
III An expansion of the categories of high-tech goods subject to an export ban, that might contribute to Russia’s military and technological enhancement.
IV A new import ban on a wide range of products and commodities, including wood, cement, chemicals and seafood, that generate significant revenues for Russia.
V A new import ban on coal and solid fossil fuels.
VI The introduction of import volume quotas for specified fertilizers, including potash.
VII A new export ban on an extensive list of low-tech goods, chemicals, commodities, and machinery, that might contribute to the enhancement of Russia’s industrial capabilities.
VIII A new export ban on jet fuel and fuel additives.
IX A new export ban on goods suited for use in liquefaction of natural gas.
X A ban on Russian-flagged vessels accessing EU ports.
XI A ban on Russian and Belarusian road transport operators transporting goods within the EU.
Exemptions may be authorised by National Competent Authorities (Department of Enterprise, Trade and Employment) from the shipping and road transport bans for imports of medical; agricultural; food; fertilisers; and energy products, and for specified metals and for humanitarian purposes.
These sanctions came into effect on 16 March 2022 and the trade provisions are set out in Council Regulation (EU) 2022/428 of 15 March 2022, amending Regulation (EU) 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine. The major trade provisions of the Regulation are as follows:
I A prohibition on the import, purchase or transport of iron and steel products, as listed in the Regulation, which originate in Russia, or which have been exported from Russia.
II A prohibition on the sale, supply, transfer or export of specific luxury goods, listed in the Regulation, to any natural or legal person, entity or body in Russia, for use in Russia.
III A prohibition on the sale, supply, transfer or export of specific goods and technology suited to use in oil exploration, production or refining, listed in the Regulation, to any natural or legal person, entity or body in Russia, for use in Russia.
IV Additional restrictions on exports intended for use in Russia’s energy sector.
V For each of the aforementioned prohibitions on trade of goods and technology, there is a corresponding prohibition on the provision of technical assistance, brokering services or other services, including financial services, related to the goods and technology.
The export prohibitions apply irrespective of whether the goods or technology originate in the EU or not.
These sanctions came into effect on 10 March 2022 and the trade provisions are set out in Council Regulation (EU) 2022/394 of 9 March 2022, amending Regulation (EC) No 833/2014 concerning restrictive measures in view of Russia's actions destabilising the situation in Ukraine. The major trade provisions of the Regulation are as follows:
I A prohibition on the sale, supply, transfer or export of maritime navigation goods and technology, listed in the Regulation, to any natural or legal person, entity or body in Russia, for use in Russia, or for placing on board of a Russian-flagged vessel.
II For each of the aforementioned prohibitions on trade of goods and technology, there is a corresponding prohibition on the provision of technical assistance, brokering services or other services, including financial services, related to the goods and technology.
The export prohibitions apply irrespective of whether the goods or technology originate in the EU or not.
These sanctions came into effect on 3 March 2022 and the trade provisions are set out in 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. These sanctions build on existing sanctions and were adopted in response to the involvement of Belarus in the Russian military aggression against Ukraine.
Previous sanctions against Belarus were introduced to address the forced landing of a flight in Minsk, Belarus on 23 May 2021 and the detention of two individuals by Belarusian authorities, as well as in response to the repeated failure of Belarus authorities to meet international electoral standards in Presidential elections and the crackdown on civil society and democratic opposition.
The major trade provisions of the Regulations are as follows:
I A prohibition on the sale, supply, transfer or export of dual-use* goods and technology to any natural or legal person, entity or body in Belarus or for use in Belarus.
II A prohibition on the sale, supply, transfer or export of 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.
III A prohibition on the sale, supply, transfer or export of specific machinery, listed in the Regulation, to Belarus or for use in Belarus.
IV A prohibition on the sale, supply, transfer or export of goods used for the production or manufacturing of tobacco products, listed in the Regulation, to Belarus or for use in Belarus.
V A prohibition on the import, purchase or transport of 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.
VI For each of the aforementioned prohibitions on trade of goods and technology, there is a corresponding prohibition on the provision of technical assistance, brokering services or other services, including financial services, related to the goods and technology.
*Dual-use goods are items that have both a civilian and military application. They are identified in REGULATION (EU) 2021/821 setting up a Union regime for the control of exports, brokering, technical assistance, transit and transfer of dual-use items.
The export prohibitions apply irrespective of whether the goods or technology originate in the EU or not.
These sanctions came into effect on 26 February 2022 and the trade provisions are set out in Council Regulation (EU) 2022/328, amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia's actions destabilising the situation in Ukraine. The major trade provisions of the Regulation are as follows:
I A prohibition on the sale, supply, transfer or export of dual-use* goods and technology, to Russia or for use in Russia.
II A prohibition on the sale, supply, transfer or export, of 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.
III A prohibition on the sale, supply, transfer or export, of specific goods and technology, listed in the Regulation, suited for use in oil refining, to Russia or for use in Russia.
IV A prohibition on the sale, supply, transfer or export, of specific goods and technology, listed in the Regulation, suited for use in aviation or space industry, to Russia or for use in Russia.
V For each of the aforementioned prohibitions on exports of goods and technology, there is a corresponding prohibition on the provision of technical assistance, brokering services or other services, including financial services, related to the goods and technology.
*Dual-use goods are items that have both a civilian and military application. They are identified in REGULATION (EU) 2021/821 setting up a Union regime for the control of exports, brokering, technical assistance, transit and transfer of dual-use items.
These prohibitions apply irrespective of whether the goods or technology originate in the EU or not.
The sanctions adopted by the EU on 23 February in response to the decision by the Russian Federation to recognise the non-government-controlled areas of the Donetsk and Luhansk oblasts of Ukraine as independent entities, remain fully in effect. The sanctions include provisions restricting certain trading activities, both export and import, with the non-government controlled Ukrainian territories of Donetsk and Luhansk.
These sanctions came into effect on 24 February 2022 and the trade provisions are set out in Council 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.
The Regulation provides that, for the specified territories of the non-government-controlled areas of the Donetsk and Luhansk oblasts of Ukraine,
I It is prohibited to import into the European Union goods originating in the specified territories.
II It is prohibited to sell, supply, transfer, or export specified goods and technology, listed in the Regulation, suited for use in the telecommunications, transport, energy and oil production sectors:
a) to any natural or legal person, entity or body in the specified territories, or
b) for use in the specified territories.
III It is prohibited to provide technical assistance or brokering services related to the goods and technology listed in the Regulation, or related to the provision, manufacture, maintenance and use of such items, to any natural or legal person, in the specified territories or for use in the specified territories.
IV It is prohibited to provide technical assistance, or brokering, construction or engineering services directly relating to infrastructure in the specified territories, in the telecommunications, transport, energy and oil production sectors, defined on the basis of the listed goods and technologies. This prohibition is independent of the origin of the goods and technology.
The Regulations cited above amend Council Regulation (EU) No 833/2014 of 31 July 2014, concerning restrictive measures in view of Russia's actions destabilising the situation in Ukraine, which was introduced in response to Russia’s illegal annexation of Crimea.
The Regulations set out specific grounds on which the exporters can apply to the Competent Authority (Department of Enterprise, Trade and Employment) for a partial or temporary exemption from the prohibitions. These grounds include use in connection with humanitarian purposes, medical applications, software updates, and for the execution of contracts entered into prior to the sanctions coming into effect. However, the grounds for derogations are much narrower in respect of specific end-users, listed in the Regulation, affiliated with the Russian military.
The requirements to avail of a derogation are precise and vary depending on the derogation being sought. Traders should closely study the details in the relevant EU Regulation.
- Department of Foreign Affairs – Information on sanctions in respect of the situation in Ukraine
- Department of Transport – EU sanctions in response to the situation in Ukraine
- Central Bank of Ireland – Russia/Ukraine Regulations
- Financial sanctions: FAQ
- Office of the Revenue Commissioners – Manual on EU sanctions in response to situation in Ukraine
- Sanctions adopted following Russia’s military aggression against Ukraine
- Notice to economic operators, importers and exporters
- Overview of EU sanctions
- Frequently asked questions: EU sanctions
- Frequently asked questions: sanctions adopted following Russia’s military aggression against Ukraine
- EU measures following the Russian invasion of Ukraine: information for customs authorities and stakeholders
- Guidance for EU operators: implementing enhanced due diligence to shield against Russia sanctions circumvention (PDF, 257KB)
- EU sanctions map
The European Commission has set up a secure, online platform to allow whistleblowers to anonymously report EU sanctions violations.
Queries regarding the trade provisions of EU sanctions should be sent to exportcontrol@enterprise.gov.ie