Fifth package of EU economic sanctions against Russia

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On 8 April 2022, the Council of the European Union (the “Council”) adopted new restrictive measures against Russia due to the ongoing conflict in Ukraine. These new sanctions complement those adopted up until 15 March 2022, which we have discussed in previous newsflashes.

Restrictive measures against individuals

The Council adopted restrictive measures against an additional 217 individuals. These include Russian high-net-worth individuals, high-ranking Kremlin officials, individuals responsible for disinformation and information manipulation, as well as family members of previously listed individuals.

These 217 individuals have been added to the list of sanctioned natural persons under Regulation (EU) No 269/2014 of 17 March 2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine. The restrictive measures include:

As of 8 April 2022, restrictive measures adopted in response to the conflict in Ukraine target a total of 1,091 listed individuals.

Restrictive measures against entities

The Council adopted restrictive measures against an additional 18 entities, which include:

These entities have been added to the list of sanctioned entities under Regulation (EU) No 269/2014 of 17 March 2014. The restrictive measures applicable to the listed entities include a freeze of their funds and economic resources, as well as a ban on making funds or economic resources available to them, in the same way that these measures apply to individuals.

As of 8 April 2022, restrictive measures adopted in response to the conflict in Ukraine target a total of 80 entities.

Restrictive measures in the banking and financial sectors

The Council amended and adopted restrictive measures in the banking and financial sectors, which include:

Restrictive measures in other sectors of the economy

The Council adopted new restrictive measures in other sectors of the economy, which include:

Our expertise

Contact our experts Philippe-Emmanuel Partsch, Marianne Brésart and Björn ten Seldam in the EU Financial & Competition Law practice for assistance understanding these measures and how they could potentially impact your activities.

This communication, which we believe may be of interest to our clients and friends of Arendt, is for general information only. It is not a full analysis of the matters presented and should not be relied upon as legal advice.


Definitions

Funds: financial assets and benefits of every kind, including, but not limited to: (i) cash, cheques, claims on money, drafts, money orders and other payment instruments; (ii) deposits with financial institutions or other entities, balances on accounts, debts and debt obligations; (iii) publicly and privately traded securities and debt instruments, including stocks and shares, certificates representing securities, bonds, notes, warrants, debentures and derivatives contracts; (iv) interest, dividends or other income on or value accruing from or generated by assets; (v) credit, right of set-off, guarantees, performance bonds or other financial commitments; (vi) letters of credit, bills of lading, bills of sale and (vii) documents showing evidence of an interest in funds or financial resources – Article 1 (g) of Regulation (EU) 269/2014

Economic resources: assets of every kind, whether tangible or intangible, movable or immovable, which are not funds but may be used to obtain funds, goods or services – Article 1 (d) of Regulation (EU) 269/2014

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Luxembourg Newsflash – Fifth package of EU economic sanctions against Russia

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