EU expands Russia sanctions package with comprehensive export bans on dual-use goods Compliance

With what is now the tenth package of sanctions, the European Union is further tightening its measures against Russia as a result of the war in Ukraine. There are new trade restrictions, particularly for industrial goods not previously covered. Companies have reason and necessity to review their own compliance measures.

The EU has further tightened sanctions against Russia in response to the war in Ukraine, which has now been going on for a year. The new legislation was published in the Official Journal of the European Union on 25.02.2023 and has therefore already entered into force.

Additions to the sanctions lists

On the one hand, the new measures expand existing sanctions lists, which have been supplemented by a total of 121 new entries for individuals and legal entities. The scope of the existing sanctions lists has thus been expanded to a total of 1473 individuals and 205 legal entities.

Expansion of restrictions on industrial goods

However, the new trade restrictions on certain industrial goods could prove to be far more drastic for German companies. In particular, the sanctions also include new export bans in the area of dual-use and advanced technology goods. This now includes additional machine parts, telecommunications equipment, optical devices, cranes, special vehicles, spare parts for trucks and engines, as well as electronic components and software. The complete list is as small as it is colorful and can be found in the Official Journal of the European Union under this link. In addition, the transit of dual-use goods is also prohibited, which is intended to prevent Russia's circumvention strategies. This may necessitate short-term logistical adjustments for companies. Finally, there are new import bans from Russia, for example on bitumen, asphalt and synthetic rubber.

Maintaining the ability to act through compliance management

The rapid entry into force of the stricter measures and the significant expansion of the goods affected, along with any necessary logistical consequences, leave the companies concerned little time for implementation. While it is still relatively easy to supplement sanctions lists with ERP systems, it can be all the more difficult to check whether your own products are also affected by new export bans. This makes it all the more important to be able to fall back on established processes in the area of compliance management, such as internal export control programs, so that implementation can take place without economic losses or the risk of own violations. To implement, introduce or review compliance management or an internal export control program, please contact your company's internal compliance or export control officer or contact us if you have any further questions.

Date: 28. Feb 2023