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The European Union has implemented its 12th package of financial sanctions against the Russian Federation, effective immediately as of 18 December 2023. This latest set of measures significantly impacts businesses with ties to Russia and includes amendments to existing regulations (EU) 833/2014 and (EU) 269/2014 through Regulations (EU) 2023/2878 and (EU) 2023/2875.

Key components of the 12th EU Russia Sanctions Package encompass a range of measures and have a profound effect on companies maintaining a presence in Russia, including those in the process of divesting.

Key measures of the 12th EU Russia Sanctions package include the following:

Controlled business services expansion

  • The prohibition on providing certain services to the Russian government or entities is expanded. This includes accounting, auditing, tax consulting, and services related to software for enterprise and industrial design.
  • A new Annex XXXIX to Regulation (EU) 833/204 specifies software items covered by this prohibition, impacting areas like enterprise resource planning (ERP), customer relationship management (CRM), business intelligence (BI), and more.


Wind down of partner country exemption

  • The EU plans to eliminate the exemption for providing controlled business services to Russian subsidiaries of companies headquartered in the EU or partner countries.
  • A six-month wind-down period, ending on 20 June 2024, will precede the elimination, requiring authorisation for continued provision of such services.


Extension of divestment licensing grounds

  • Deadlines for licensing grounds related to the sale, supply, licensing, import, or transfer of controlled items and the provision of controlled business services for divestment from Russia are extended to 30 June 2024, 31 July 31 2024, or 30 September 2024, depending on the relevant sanction.


Ban on Russian diamonds

  • A new Article 3p introduces a phased import ban on diamonds and jewellery made from Russian diamonds starting 1 January 2024.
  • Additional bans extend to Russian diamonds processed in third countries, with requirements for traceability-based evidence from importers.


Additional import and export bans

  • Import bans on items generating significant revenues for Russia, including pig iron, spiegeleisen, copper wires, aluminium wires, foil, tubes and pipes.
  • A new import ban on liquefied propane (LPG) with a 12-month transitional period.
  • Export bans on items contributing to Russia’s military and technological enhancement, with tighter restrictions on dual-use items.


Transit ban expansion

  • The transit ban, initially on dual-use items exported from the EU to third countries via Russia, is extended to certain industrial items listed in Annex XXXVII to Regulation (EU) 833/2014.


Oil price cap enforcement measures

  • Strengthened information sharing mechanism requiring businesses to share price information for ancillary costs throughout the supply chain of Russian oil trade.
  • Notification rules for the sale of tankers to any third country to increase transparency, particularly for second-hand carriers.


"No Russia" clause

  • Imposition of a requirement on EU exporters to insert contractual clauses prohibiting re-exports to Russia and re-exports for use in Russia of particularly sensitive items.
  • The clause applies retrospectively to agreements concluded before 19 December 2023, with a transition period until 20 December 2024, or their expiry date.


Iron and steel measures

  • Introduction of Annex XXXVI listing partner countries with equivalent import control measures on iron and steel.
  • Extension of wind-down periods for the import of specific steel products.


Personal use exemption and crypto-asset measures

  • Exemptions for personal use items and diplomatic vehicles.
  • Ban on Russian nationals owning or controlling entities providing crypto-asset services.


Additional designations

  • Designation of 61 individuals and 86 entities in various sectors, including defence, IT, and the direct listing of a Russian insurance company.


Final considerations

For businesses in Cyprus, the 12th EU Russia Sanctions Package holds particular importance due to the nation's economic ties and geopolitical considerations. As Cyprus maintains connections with both the EU and Russia, local businesses may experience challenges and disruptions in sectors impacted by the sanctions. It is crucial for Cypriot enterprises to assess the implications of these measures on their operations, trade relations, and financial transactions. Navigating through the complexities of the sanctions will require strategic adjustments and compliance measures to mitigate potential risks and ensure continued stability in the face of evolving geopolitical dynamics.


For more information please visit our website microsite on AML Compliance, Sanctions and Investigations or send your queries at This email address is being protected from spambots. You need JavaScript enabled to view it..

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