Upstract Image1

Related Practice Areas

Related Practice Areas

Upstract Image2

Related Industry Sectors

Related Industry Sectors


On 24 February 2023 the European Union (“EU”) has approved a tenth package of Russia sanctions. The package includes tighter export restrictions regarding dual-use goods as well as measures against entities supporting the war, spreading propaganda or delivering drones used by Russia. Specifically, this package contains the following elements:

Additional listings

The EU has added about 121 individuals and entities to the sanction 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 Ukraine, among others. The list also includes 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. Measures are also taken against individuals in Iran who are 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, are also targeted.

Additional EU export bans and restrictions

New export restrictions have been introduced on sensitive dual-use and advanced technologies that contribute to Russia's military capabilities and technological enhancement, based on information received from Ukraine, our Member States and our partners. This includes additional electronic components used in Russian weapons systems (drones, missiles, helicopters, other vehicles), as well as bans on specific rare earths and thermal cameras with military applications. Moreover, we are also listing 96 additional entities associated to Russia's military-industrial complex, bringing the total of military end-users that are listed to 506. This includes, for the first time, seven Iranian entities that have been using EU components and providing Russia with military "Shahed" drones to attack civilian infrastructure in Ukraine. Importantly, we are working in close coordination with partners, and are adding Australia, Canada and New Zealand and Norway to the list of our partner 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, compass, etc.;
  • Construction goods such as bridges, structures for buildings tower-like, fork-lifts trucks, cranes, etc.;
  • Goods that are critical for the functioning and enhancement of Russian industrial capacity (electronics, machine parts, pumps, machinery for working metals, etc.);
  • Complete industrial plants: this category has been added to avoid loopholes;
  • Goods used in the aviation industry (turbojets).


These new bans and restrictions cover EU exports worth EUR 11.4 billion (2021 data). They come on top of the €32.5 billion worth of exports already sanctioned in the previous packages. With today's package, the EU has sanctioned in total nearly close to half (49%) of its 2021 exports to Russia.

Additional imports bans into the EU

Today's package imposes import bans on the following Russian high-revenue goods:

  • Bitumen and related materials like asphalt;  and
  • Synthetic rubber and carbon blacks.

These new import bans cover EU imports worth almost EUR 1.3 billion and they come on top of €90 billion already sanctioned, representing altogether 58% of the EU's 2021 imports.

Financial sector

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 new banks that have been sanctioned are Alfa-Bank JSC, PJSC Rosbank, and Tinkoff Bank JSC.

Other measures include the following:

  • A ban on Russian nationals from serving on governing bodies of Member States' critical infrastructure companies;
  • Prohibition on Russian nationals and entities to book gas storage capacity in the Union (LNG excluded);
  • Measures to facilitate the divestment from Russia by EU operators;

A third country shipping company, suspected of helping Russia circumvent sanctions on oil exports, has also been listed.


Enforcement and anti-circumvention measures

This tenth package imposes new reporting obligations on Russian Central Bank assets. This is especially important regarding the possible use of public Russian assets to fund the reconstruction of Ukraine after Russia is defeated.

Other measures include the following:

  • reporting obligations on frozen assets (including for dealings before listings) and assets which should be frozen;
  • Private flights between the EU and Russia, directly or via third countries, should be notified in advance;
  • Prohibition to transit dual use goods and firearms via the territory of Russia to third countries.

In addition to this tenth package, the EU sanctions envoy David O'Sullivan is reaching out to third countries, to ensure strict implementation of sanctions and prevent circumvention. On 23 February, the first Sanctions Coordinators Forum took place in Brussels, gathering our international partners and Member States, to strengthen enforcement efforts.


Additional bans on Russian disinformation outlets

Two additional Russian media outlets have been added to the media ban, RT Arabic and Sputnik Arabic.

Technical amendments

  • Amendment to allow the provision of pilot services necessary for maritime safety ;
  •  Definition of the term “import” to avoid goods being “stranded” in long customs procedures;


By  Dorita Michaelidou

For more information, please contact any of our lawyers in the AML Compliance and Sanctions team or at This email address is being protected from spambots. You need JavaScript enabled to view it.


Back to News

1 Kinyra Street, 5th floor
1102 Nicosia


115 Faneromenis Avenue,
Antouanettas Building
6031 Larnaca


12 Platonos Street,
3027 Limassol


4 Nicou Nicolaidi & Kinyra,
2nd floor, 8011 Paphos


164A Georgiou Gourounia,
1st floor, 5289 Paralimni

Monday – Thursday

8:00 – 18:00


8:00 – 16:00

TEL: +357 24 201 600

FAX: +357 24 201 601

Privacy Policy