The EU Issues a Ninth Package of Sanctions Against Russia

Right before the end of the year, on December 16, 2022, the EU adopted the ninth package of sanctions against Russia. This new package includes additional designations, export control restrictions, additional service and media bans, and new sectoral measures targeting the Russian energy and mining sectors.

In more detail, the new sanctions package includes restrictions such as:

• Additional designations. The EU has designated almost 200 individuals and entities. This includes the Russian armed forces, as well as individual officers and defense industrial companies, members of the State Duma and Federation Council, ministers, and Russian proxy authorities in occupied areas of Ukraine and political parties, among others. This also includes two new Russian banks (Credit Bank of Moscow and Dalnevostochny Bank).The EU has also issued a full transaction ban on the Russian Regional Development Bank.

• Additional export bans. New export controls and restrictions have been introduced on sensitive dual-use and advanced technologies that contribute to Russia’s military capabilities and technological enhancement. This includes drone engines, camouflage gear, additional chemical/biological equipment, riot control agents, and additional electronic components found in Russian military systems on the battlefield. Export bans have also been extended to additional industrial goods and technology, such as toy/hobby drones, complex generator devices, laptop computers and computing components, printed circuits, radio navigational systems, radio remote control apparatus, aircraft engines and parts of engines, cameras, and lenses.
• Restrictions on the exports of drones. The direct export of drone engines to Russia and the export to any third countries, such as Iran, where there is a suspicion that they will be used in Russia is now restricted.
• Additional bans on Russian media outlets. Four Russian channels—NTV/NTV Mir, Rossiya 1, REN TV, and Perviy Kanal—have been sanctioned in the EU.
• Bans on the provision of certain services. After the eighth package prohibited the provision of certain services, including legal services, now the EU has also issued a ban on the provision of market research and public opinion polling services, technical testing and analysis services, and advertising services.
• Restrictions on new investment in the Russian mining sector. In addition to the already-existing investment ban on the energy sector in Russia, new EU investments in the Russian mining sector are also now prohibited, with the exception of certain raw materials.

The EU has published additional guidance on its latest package of restrictive measures, available here. The EU’s ninth package of sanctions comes on top of the full EU import ban on Russian seaborne crude oil (see Winston & Strawn LLP’s Global Trade & Foreign Policy Insights publication on the EU’s eighth package of sanctions against Russia). Both the ban on Russian seaborne crude oil and the global oil price cap agreed to by G7 partners apply from December 5.

2022 was a year where the U.S., EU, and other ally countries continuously updated their sanctions against Russia. Companies should remain vigilant for 2023 and continue to assess their exposure to the ever-changing Russian sanctions.