Following the publication of the now 13th sanctions package by the European Union on February 23, 2024, AEB has analyzed the restrictive measures issued, and provides information on how AEB applications can support you.
Depending on the business area of your company, evaluate which restrictive measures are relevant and therefore need to be implemented in the software and in the organization within the company (ICP). Also check the websites of EU, US, or national authorities for the latest content of sanctions measures. You can find some useful links below.
- The practical implementation of sanctions measures in the company requires comprehensive expertise in the areas of sanctions law and export control. Read here about the options for implementing or screening these various sanction measures in AEB Trade Compliance.
EU sanctions
Part of the new sanctions measures are based on EU regulations in place since 2014 laid down in response to the annexation of the Crimean Peninsula with respect to Russia's actions. These embargo regulations were extended in 2022, 2023, and 2024. The consolidated, non-official version can be selected via the respective date in the left-hand column under “hide/all consolidated versions”:
- Council Regulation (EU) No. 269/2014 of March 17, 2014
- Council Regulation (EU) No. 692/2014 of June 23, 2014
- Council Regulation (EU) No. 833/2014 of July 31, 2014
As a reaction of the EU to Russia's annexation of Ukraine's Donetsk and Luhansk regions, further sanctions were decided against Russia with respect to these areas. These were later expanded to include Kherson and Zaporizhzhya.
Together, these embargo regulations form the legal basis for the Russia embargo.
This official info graphic published by the EU Council shows the variety of sanctions that the EU has currently enacted against Russia. The sanctions measures currently in place against Russia can be divided into the following four categories:
The sanctions measures currently in place against Russia can be divided into the following four categories:
- Personal financial sanctions (bans on direct and indirect provisions)
- Capital market restrictions
- Goods-related restrictions (prohibitions, license requirements)
- Trade restrictions for the regions Crimea, Kherson, Donetsk, Luhansk, and Zaporizhzhya
Personal financial sanctions (bans on direct and indirect provisions)
Financial sanctions are directed against certain persons, companies, and organizations listed in the annex to the corresponding regulation. The listed entities are subject to comprehensive bans on direct and indirect provisions. The sanctioned entities are added to the CFSP list. The CFSP list is the official EU database that consolidates all persons, companies, and organizations subject to EU financial sanctions.
With regard to the Russia embargo, financial sanctions were ordered in Article 2 of Regulation (EU) No. 269/2014. The entities subject to these measures are listed in Annex I to this regulation.
The CFSP list is available to all Compliance Screening users as part of the basic sanctions list package. As soon as the publishing authorities make the electronic versions available, the sanctions lists are updated in Compliance Screening with a nightly batch.
Include your business partners in the compliance profile to screen them against the CFSP list using Compliance Screening.
- Please note that financial sanctions also provide for the ban on indirect provisions. If a non-listed entity is owned by a listed entity, the ban on indirect provisions also applies indirectly to the non-listed entity. For automated majority ownership support in Compliance Screening, AEB offers Dow Jones' paid SCO (Sanctions Control and Ownership) content.
Capital market restrictions
The restrictions on access to the capital market are ordered in detail in Article 5ff. of Regulation (EU) 833/2014. These sanctions apply generally in connection with Russian companies, conglomerates, or banks listed, for example, in Annexes III, V, VI, XII, or XIII. These sanctions concern certain capital, investment, and securities transactions with the listed entities or Russian financial authorities.
If these restrictions are relevant for your company, screen your business partners against the EUCM’s “EU – Restrictions on access to the capital market” sanctions list using Compliance Screening. This list is available as one of the AEB standard lists and can be included in the used check profile, if required.
- In general, if sanctions (both financial sanctions and capital market restrictions or restrictions on trade in dual-use goods) are directed against specific entities, they can be screened using Compliance Screening and the corresponding sanctions lists either automatically or in manual individual checks.
Goods-related sanctions
Regulation (EU) 833/2014 provides for various goods-related sanctions. In the annexes to this embargo regulation, there are several lists of companies that are prohibited from trading in dual-use or "advanced technology" goods, as well as various lists of goods whose export to Russia is prohibited.
Goods-related sanctions are also ordered in the Embargo Regulations (EU) 692/2014 (Crimea) and (EU) 2022/263 (Donetsk, Luhansk, Kherson, Zaporizhzhya). The specifics are described in the next chapter “Trade restrictions for some regions of Ukraine”.
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Restrictions on goods with respect to certain Russian entities
Parts of Regulation (EU) 833/2014 include a prohibition to sell, deliver, transfer, or export dual-use goods to the listed entities (Annex IV). To screen this, include EUDU “Restrictions for dual-use goods intended for listed organizations” sanctions list in the Compliance Screening check profile.
Most goods restrictions apply regardless of the specific recipient in Russia. Taking into account your company's business or product portfolio, in addition to Compliance Screening, the other components of the Trade Compliance software, such as Export Controls, License Management, or Risk Assessment, may also be required for the implementation of the Russia embargo. -
Goods restrictions regardless of the recipient
By Regulation (EU) 833/2014, a prohibition exists to export, sell, and transfer or supply any dual-use goods and technologies listed in Annex I of the EU Dual-Use Regulation to Russia or for use in Russia, regardless of the recipient or end-user (Art. 2). The same prohibition also applies to Annex VII goods, the “advanced technology goods” (Art. 2a). Transit through the territory of Russia of goods and technology listed in Annex XI that are suitable for use in the aerospace industry or of aviation turbine fuels and fuel additives listed in Annex XX is also prohibited. Regulation (EU) 833/2014 contains other lists of goods that are subject to various restrictions in connection with Russia.- Please note that Compliance Screening is not intended for checking export or import restrictions that apply independently of the specific business partner (recipient) and relate to specific goods. You can map and check such goods-related embargo rules using Export Controls.
If you implement goods-related restrictions for your company using Export Controls from AEB, consider whether they affect imports from Russia or exports to Russia. For example, there are import bans on diamonds listed in Annex XXXVIIIA and products containing diamonds as well as on iron or steel products listed in Annex XVII of Regulation EU 833/2014. In contrast, the restrictions on, for example, goods for oil refining (Annex X), aerospace (Annex XI), maritime shipping (Annex XVI) or luxury goods (Annex XVIII) include export bans.
To implement goods-related restrictions, you must first enhance the master data in Export Controls (Master data you can maintain for Export Controls). This mainly concerns the goods attributes and the lists of goods relevant for your company.
- The EU dual-use list, the German export control list, and the US Commerce Control List are the standard master data that AEB always keeps up to date. You can use these lists of goods and your own goods attributes to map the restrictions relevant to your company using manual restrictions.
In the article Maintaining master data required for manual restrictions you will find the necessary steps to configure the embargo rules as manual restrictions.
Trade restrictions for some regions of Ukraine
Another part of the EU sanctions was introduced by Regulation (EU) 692/2014 (concerns Crimea) and Regulation (EU) 2022/263 (concerns Kherson, Donetsk, Luhansk, and Zaporizhzhya). These include import bans for goods originating from the specified areas into the EU and export bans to the specified areas for goods listed in Annex II of the relevant regulation.
- If you are affected by this, you must take action to map these restrictions in Trade Compliance Management. In Export Controls and Compliance Screening, you use the functionalities for defining “areas” for this purpose.
Since Ukraine as a whole is not an embargoed country and only deliveries of goods from or to individual regions are sanctioned, this function let’s you define an embargo specifically for these areas. Use a combination of postal codes and/or cities and add them to the check profile. The area can be optionally stored in Compliance Screening (as a restricted part list) or in Export Controls (as a manual restriction).
Postal codes in Ukraine have 5 digits and are unique for each region.
- Kherson region has postal code zones 73000-75999
- Donetsk region has postal code zones 83000-87999
- Luhansk region has postal code zones 91000-94999
- Zaporizhzhia region has postal code zones 69000-72999
- Crimea region has postal code zones 95000-99999 or
6 digits for Russian Post 295000-299999
Tips & Tricks
Compliance Screening: Screening against embargo areas defined by you
Export Controls: Export Controls: Defining areas and configuring manual restrictions
Sanctions of other countries
Other states have ordered similar national sanctions measures, such as personal financial sanctions or restrictions on trade in certain goods, against Russia or against the Crimea, Luhansk, or Donetsk regions. More details can be found on websites of national authorities.
Comments
The article "Current developments in the conflict between Russia and Ukraine" was updated today with the current status of March 2, 2022.
The article “Implementation and screening of the Russia embargo in AEB Trade Compliance Management” was completely revised at the end of April 2022 to give you access to the latest regulations.
It also includes links to detailed instructions on the implementation in Trade Compliance Management.
After the European Union's sixth sanctions package came into force on June 4, 2022, check whether further adjustments in trade compliance management will be necessary for your business. All current links, e.g. to the Federal Office of Economics and Export Control (BAFA), the Council of the EU, or to the consolidated regulations are included in the article.
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