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:
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:
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 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:
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
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.
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