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On October 6, 2022, the European Union (the EU) adopted the eighth package of restrictive measures (sanctions) against Russia in response to “Russia's continued escalation and illegal war against Ukraine, including by illegally annexing Ukrainian territory based on sham “referenda”, mobilizing additional troops, and issuing open nuclear threats”.

The new sanctions include a series of measures intended to increase the pressure on the Russian government and economy, weaken Russia's military capabilities and make the Kremlin pay for the recent escalation. The new measures were imposed through four Council Regulations and three Council Decisions.

In addition to individual restrictive measures which include new designations, trade sanctions and sanctions on transport and crypto-assets, the eighth package of sanctions includes important prohibitions on the provision of legal advisory services to the Government of Russia or Russian entities.  Specifically, the provision of legal advisory services to the Government of Russia or Russian entities is prohibited subject to a number of exemptions, which are as follows:

  • Legal services which are strictly necessary for the termination by January 8, 2023, of “prior contracts” concluded before October 7, 2022;
  • Legal services which are strictly necessary for the exercise of the right of defense in judicial proceedings and the right to an effective legal remedy;
  • Legal services which are strictly necessary to ensure access to judicial, administrative or arbitral proceedings in a Member State, or for the recognition or enforcement of a judgment or an arbitration award rendered in a Member State, provided that such provision of services is consistent with the objectives of Regulations 833/2014 and Regulation 269/2014;
  • Legal services which are intended for the exclusive use of legal persons, entities or bodies established in Russia that are owned by, or solely or jointly controlled by, a legal person, entity or body which is incorporated or constituted under the law of a Member State, a country member of the European Economic Area, Switzerland or a partner country as listed in Annex VIII;
  • Legal services which are necessary for public health emergencies, the urgent prevention or mitigation of an event likely to have a serious and significant impact on human health and safety or the environment, or as a response to natural disasters;
  • Legal services which are necessary for software updates for non-military use and for a non-military end user, where permitted under export-related restrictions (with reference made to Articles 2(3)(d) and 2a(3)(d) in relation to goods listed in Annex VII of regulation 833/2014).


Derogations apply for the provision of the aforementioned services, whereby authorizations can be requested where the aforementioned services are necessary for:

  • Humanitarian purposes;
  • Civil society activities that directly promote democracy, human rights or the rule of law in Russia;
  • The functioning of diplomatic and consular representations of the EU, Member States or partner countries in Russia;
  • Ensuring critical energy supply within the Union and the purchase, import or transport into the Union of titanium, aluminum, copper, nickel, palladium and iron ore;
  • Ensuring the continuous operation of infrastructures, hardware and software which are critical for human health and safety, or the safety of the environment;
  • The establishment, operation, maintenance, fuel supply and retreatment and safety of civil nuclear capabilities, and the continuation of design, construction and commissioning required for the completion of civil nuclear facilities, the supply of precursor material for the production of medical radioisotopes and similar medical applications, or critical technology for environmental radiation monitoring, as well as for civil nuclear cooperation, in particular in the field of research and development; or
  • The provision of electronic communication services by Union telecommunication operators necessary for the operation, maintenance and security, including cybersecurity, of electronic communication services, in Russia, in Ukraine, in the Union, between Russia and the Union, and between Ukraine and the Union, and for data center services in the Union.


In addition, the exemption for restrictions on services related to trusts and similar legal arrangements has been extended to situations where the trustor or beneficiary is an EEA or Swiss citizen, in addition to EU citizens and EU, EEA or Swiss residents.

For more information, you can contact one of our lawyers shown in the right panel of our AML Compliance and Sanctions page or send your queries at This email address is being protected from spambots. You need JavaScript enabled to view it.

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