EU's sixth sanctions package has entered into force

Last week, after almost a month of negotiations, the EU member states finally reached an agreement on the sixth sanctions package against Russia. The new wave of sanctions entered into force over the weekend.

Already at the time of publishing the fifth sanctions package, Ursula von der Leyen was hinting that an import ban on Russian oil could be next. Last week, that hint finally became a reality as the sixth sanctions package entered into force, effectively banning the import of Russian oil (with certain exemptions). 

The phasing out of crude oil will be completed on 5 December 2022, while the phasing out of other refined petroleum products will be completed on 5 February 2023. Certain exemptions apply for countries which are dependent on Russian oil.

The import ban on oil has been the subject of much discussion and media coverage, and while it is undoubtedly the most radical part of the sixth sanctions package, it is important to note that it is just one of the elements of the new sanctions package which also encompasses several other new restrictive measures, including: 

Further banks subject to SWIFT-ban

Three additional Russian banks are banned from the SWIFT-network. 

Most notably, Sberbank, the largest bank in Russia, will be added to the list. The two remaining banks are Credit Bank of Moscow and Joint Stock Company Russian Agricultural Bank, JSC Rosselkhozbank.

This adds the total list of "de-SWIFT'ed" Russian banks to ten banks. The ban will take effect on 14 June 2022.

Simultaneously, the Belarusian bank, Belinvestbank, will also be banned from the SWIFT network. 

Ban of state-owned broadcasters

A ban is imposed on three Russian state-owned broadcasters, who will no longer be able to broadcast on European airwaves:

  1. Rossiya RTR / RTR Planeta,
  2. Rossiya 24 / Russia 24, and
  3. TV Centre International. 

These three broadcasters join Russia Today and Sputnik, who were already banned from broadcasting in the EU.

The wording of the prohibition in the regulation has been slightly amended to also include a prohibition on "advertising products or services in any content produced or broadcast" by the sanctioned Russian media outlets.

Ban on consultancy services

A ban is imposed on the provision of accounting, auditing, including statutory audit, bookkeeping or tax consulting services, or business and management consulting or public relations services to the government of Russia or any legal persons, entities or bodies established in Russia. 

An important derogation to the prohibition has been inserted, allowing the provision of the beforementioned services if it is intended for the exclusive use of companies 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, effectively allowing the provision of such services to Russian subsidiaries of EU companies.

Further targeted sanctions

Adding to the current list of more than a thousand individuals and entities, further targeted sanctions are imposed against 65 individuals and 18 entities, primarily consisting of high-ranking military officers and individuals who are known to have committed war crimes in Bucha as well as entities known for producing material to the Russian military. 

A new excemption has been adopted for the making available of funds or economic resources that are strictly necessary for the provision of electronic communication services by Union telecommunication operators and associated facilities and services. 

Minor additions to existing prohibitions

In addition to the above, certain minor additions to the existing prohibitions have been made as well. By way of example, new products have been added to the list of goods and technology which may contribute to the technological enhancement of Russia's defense and security sector, and which may therefore not be exported to or sold in Russia, while spirits, liqueurs and other spirituous beverages have been added to the list of goods subject to an import ban.

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