Russia embargo: Overview and screening with AEB Trade Compliance Management

Following the publication of the 16th sanctions package by the European Union on February 24, 2025, AEB has analyzed the new regulations and provides information on how AEB applications can support you.

The practical implementation of sanctions measures in the company requires 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.

• Check relevant measures for your company
  Every company is affected differently by sanctions. The restrictions that apply depend on your business area and the products you trade in. Analyze which measures are relevant for your company.
• Integrate changes into your compliance organization and AEB software
  Adapt your internal compliance organization (ICP) and check the extent to which AEB applications can support you with the implementation. In addition to restricted party list screening with Compliance Screening, it may be necessary to use other trade compliance modules such as Export Controls, License Management, or Risk Assessment in order to comply with the Russia embargo.
• Stay informed about current developments
  Use the websites of EU, US, and national authorities to stay up to date. You can find some useful links below.
• Go to EU Council website on the Russia embargo

EU sanctions

A large part of the sanction measures are based on the EU regulations in force since 2014, which were issued following the annexation of Crimea and significantly tightened in the years 2022-2025. The following regulations for the legal basis:

• Regulation (EU) 269/2014 – Personal financial sanctions
• Regulation (EU) 833/2014 – Economic sanctions against Russia
• Regulation (EU) 692/2014 – Trade restrictions for Crimea
• Regulation (EU) 2022/263 – Sanctions against the Donetsk, Luhansk, Kherson, and Zaporizhzhya regions

The current sanctions against Russia, which are set out in the above-mentioned regulations, can be divided into four main categories:

1. Personal financial sanctions (bans on direct and indirect provisions)
2. Goods-related restrictions (prohibitions, license requirements),
3. Capital market restrictions
4. Trade restrictions for the regions Crimea, Kherson, Donetsk, Luhansk, and Zaporizhzhya

1. Personal financial sanctions in Compliance Screening

Financial sanctions are directed specifically against certain persons, companies, and organizations listed in the annexes to the corresponding regulations. These listed names are subject to comprehensive bans on the provision of economic or financial resources. The sanctioned names are added to the CFSP list – the official EU database that centrally records all persons, companies, and organizations subject to financial sanctions by the EU.

As part of the Russia embargo, financial sanctions are defined in Article 2 of Regulation (EU) No. 269/2014. The affected natural and legal persons are summarized in Annex I to this Regulation and in the CFSP list. The other EU regulations on the Russia embargo do not contain any lists of names to which bans on the provision of economic or financial resources apply.

The CFSP list is generally available in all Compliance Screening applications as part of the basic sanctions list package. As soon as the competent authorities publish a new version, the list is automatically updated via the nightly batch process in Compliance Screening.

Include your business partners in the check 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.

2. Goods-related restrictions in Compliance Screening and Export Controls

Regulation (EU) 833/2014 provides for various goods-related sanctions. The annexes to this embargo regulation list both companies that are excluded from trade in dual-use and advanced technology goods and goods whose export to Russia or import from Russia is prohibited.

Goods-related sanctions are also defined in Regulations (EU) 692/2014 (Crimea) and (EU) 2022/263 (Donetsk, Luhansk, Kherson, Zaporizhzhya). The specific regulations are explained in the last chapter "Trade restrictions for some regions of Ukraine".

• Restrictions on goods for certain Russian companies and organizations
  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 comply with these provisions, include EUDU “Restrictions for dual-use goods intended for listed organizations” sanctions list in the Compliance Screening check profile.

• Restrictions on goods depending on the business area
  Most goods-related sanctions apply regardless of the recipient in Russia and affect certain goods directly. This means that the export or use of these goods in Russia is generally prohibited – even if the trading partner is not explicitly on a sanctions list.

According to Regulation (EU) 833/2014, a prohibition exists to export, sell, and transfer or supply any dual-use goods listed in Annex I of the EU Dual-Use Regulation and advanced technology goods listed in Annex VII, regardless of the recipient or end-user (Art. 2, 2a). In addition, the regulation contains over 20 other lists of goods that regulate various restrictions in connection with Russia. These include luxury goods (Annex XVIII), goods to strengthen Russia's industrial capacities (Annex XXIII), the List of Common High Priority Items (Annex XL), etc.

• These sanction measures cannot be mapped and checked via Compliance Screening, as they apply independently of the business partner. You can ensure compliance via AEB Export Controls, which requires the corresponding master data.

• Companies should check whether imports from or exports to Russia are affected. For example, there are import bans on diamonds and products containing diamonds (Annex XXXVIIIA) and on iron and steel products (Annex XVII). In contrast, export bans apply, for example, to goods for oil refineries (Annex X) or luxury goods (Annex XVIII).
  To implement goods-related restrictions, you first need to expand the master data in Export Controls (Master data you can maintain for Export Controls). 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.

3. Capital market restrictions and other 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. In addition, Regulation (EU) 833/2014 contains a list of Russian media participating in propaganda activities (Annex XV), as well as various other lists, such as a list of ships (Annex XLII).

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.

• In general, if sanctions (both financial sanctions and capital market restrictions or restrictions on trade in dual-use goods) are directed against specific entities or persons, they can be screened using Compliance Screening and the corresponding sanctions lists either automatically or in manual individual checks.

4. 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
• Zaporizhzhya region has postal code zones 69000-72999
• Crimea region has postal codes 95000-99999 or 6 digits for Russian Post 295000-299999

Instructions

Compliance Screening: Screening against embargo areas defined by you

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.

United States

• Go to OFAC website (US)
• Go to BIS website (US)

United Kingdom

• Go to gov.uk website (UK)
• Go to Russia Sanctions Guidance (UK)

Switzerland

• Go to SECO website (CH)

Canada

• Go to Government of Canada website (CA)

Australia

• Go to DFAT website (AU)