The EU has recently extended the duration of some of its sanctions imposed in connection with the crisis in Ukraine. The extension relates to the sectoral sanctions against Russia as well as the Crimea and Sevastopol sanctions.

Sectoral sanctions

Pursuant to the Council Decision (CFSP) 2015/971 the period of application of the EU’s sectoral sanctions against Russia imposed by the Council Decision 2014/512/CFSP (as amended) is extended until 31 January 2016.

In summary, the sectoral sanctions affecting Russia contain restrictions/prohibitions on:

  • capital markets and financing transactions involving specified Russian banks and other entities;
  • import/export of military and dual use goods and technology to/from Russia as well as related technical assistance, financing and financial assistance; and
  • export to Russia of specified oil-related equipment as well as the provision of specified services in the oil sector.

It should be emphasised that sectoral sanctions are complex and careful analysis of a transaction is required for compliance purposes.

Crimea and Sevastopol Sanctions

Pursuant to the Council Decision (CFSP) 2015/959 the Crimea and Sevastopol sanctions (imposed by Council Decision 2014/386/CFSP (as amended)) have been renewed for one year and now expire on 23 June 2016 (unless extended further).

In essence, the EU has imposed a general embargo on most business transactions related to Crimea and Sevastopol as the measures include prohibitions on:

  • the import into the EU of goods from Crimea and Sevastopol as well as the provision of related services;
  • the acquisition of real estate or entities (including creation of joint ventures) in the region;
  • the granting of any financing or the provision of investment services;
  • the sale/supply of goods into Crimea in specified key sectors as well as the provision of related services; and
  • the provision of services related to tourism.

Other EU Ukraine-related measures

Other measures introduced by the EU in response to the Ukraine crisis comprise:

  • a freeze of all assets owned or controlled by specified individuals and entities;
  • prohibition against funds or economic resources being made available to or for the benefit of them; and
  • EU travel ban on the specified individuals.

The above measures apply to two categories of persons:

  1. those said to be responsible for the misappropriation of Ukrainian state funds and human rights violations in Ukraine (Council Decision 2014/119/CFSP (as amended)); and
  2. those said to be responsible for the undermining or threatening the territorial integrity, sovereignty and independence of Ukraine (Council Decision 2014/145/CFSP (as amended)).

The measures applicable to the first category of persons are currently in force until 6 March 2016 (except that with respect to one person only they apply until 6 October 2015). The measures applicable to the second category are currently in force until 15 September 2015.

On 14 July 2015 the EU also published a notice that it intends to amend the statements of reasons for the listing of some of the persons in the second category. Such persons are entitled to submit a request to the Council to obtain the intended statement of reasons for their designation, before 31 July 2015.

If you have any queries as to how the Ukraine-related sanctions may affect your business or personal affairs please contact Nick Neocleous or Alexander Muksinov.

Please note that this blog is provided for general information only. It is not intended to amount to advice on which you should rely. You must obtain professional or specialist advice before taking, or refraining from, any action on the basis of the content of this blog.

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