There are new sanctions rules against Russia. The so-called “20th sanctions package” was actually supposed to appear as early as the anniversary of the invasion of Ukraine at the end of February. It failed to be adopted at that symbolic point in time due to Hungary’s blockade. Following the change of government there, it has now been possible to adopt it.<\/p>\n\n\n\n
The new sanctions package no longer contains as many new individual prohibitions. Instead, as expected, it extends existing prohibitions with regard to goods and persons. It places greater emphasis on preventing circumvention. The focus is now increasingly on enforcement, control, and global coordination<\/strong>. The aim is to enforce the sanctions already in place.<\/p>\n\n\n\n For the first time, the EU is activating the anti-circumvention instrument against Kyrgyzstan. Under Article 12f(3) of Regulation (EU) No 833\/2014, Annex XXXIII to that Regulation may list countries “that have been identified by the Council as having systematically and persistently failed to prevent the sale, supply, transfer or export to Russia of goods and technology, as listed in that Annex, exported from the Union, despite the Union\u2019s prior outreach and assistance to the country in question.” This possibility has existed since 23 June 2023, but the EU has now, for the first time, made use of this mechanism and listed Kyrgyzstan in respect of goods under CN codes 8457 10 and 8517 62. The export, transfer, supply, or sale of these goods to Kyrgyzstan is prohibited.<\/p>\n\n\n\n The stated reasoning is that, although the International Special Envoy for the Implementation of EU Sanctions has actively cooperated with the Kyrgyz Republic, and the Union has, in addition, held technical consultations with the Kyrgyz authorities, the Union nonetheless considers that Kyrgyzstan has not taken sufficient measures to ensure that Common High Priority Items (CHPIs) originating in the Union are not re-exported to Russia.<\/p>\n\n\n\n According to the EU Commission, this is borne out by the available trade data for the first ten months of 2025. According to that data, imports of Common High Priority Items from the Union into the Kyrgyz Republic were almost 800% above the level prior to Russia’s war of aggression against Ukraine. Over the same period, the level of exports of Common High Priority Items from the Kyrgyz Republic to Russia was 1,200% higher than before Russia’s war of aggression.<\/p>\n\n\n\n Affected above all are companies in the machine tool industry, whose goods may no longer be supplied to Kyrgyzstan. The trade volume is not particularly high, as we understand from the market. Nevertheless, this measure represents a new dimension of EU legislative action: now that a third country, Kyrgyzstan, has for the first time been directly sanctioned in respect of specific goods, it can be expected that other countries will likewise come into focus in order to prevent circumvention.<\/p>\n\n\n\n What other individual measures were adopted?<\/strong> The further import restrictions are intended to prevent revenue for Russia; they concern certain raw materials, metals, and certain minerals, scrap of steel and other metals, chemicals, goods made of vulcanised rubber, and tanned furskins.<\/p>\n\n\n\n The Union has taken measures to identify organisations that enable Russia to continue obtaining funding for its war of aggression against Ukraine, either by participating in the System for Transfer of Financial Messages (SPFS) of the Central Bank of the Russian Federation, or by enabling the circumvention of the Union’s restrictive measures, and to prohibit any transactions between these organisations and economic operators from the Union.<\/p>\n\n\n\n The energy sector is also in focus, above all the so-called shadow fleet. The groundwork has been laid, in a coordinated manner, for a future comprehensive maritime transport ban in connection with Russian crude oil and Russian petroleum products. In addition, the aim is to prevent Russia from putting sold tankers to a particular end use. To this end, the revised Article 3q now provides for dedicated due diligence requirements as well as a mandatory “no-Russia clause.”<\/p>\n\n\n\n Further vessels are being added to Russia’s shadow fleet under Annex XLII to Regulation (EU) No 833\/2014. Under Article 3s of that Regulation, these vessels are subject to a port access ban as well as a prohibition on providing services to them. New prohibition clauses have also been introduced with regard to the discharging of LNG.<\/p>\n\n\n\n Now that the Union and partner countries have imposed restrictive measures that have significantly curtailed Russia’s ability to access international markets and procure military equipment, as well as listed persons’ ability to carry out financial transactions, new circumvention mechanisms have emerged. These mechanisms include operators outside the financial sector who grant access to payments from third countries through legal entities under their control or through participating intermediaries, as well as the activities of operators offering services that provide access to systems enabling international transactions to be carried out without cross-border payments, through alternatives such as netting, clearing, matching, or settlement. In order to render such circumvention practices ineffective, transactions are prohibited with economic operators found to be offering services that enable international transactions circumventing the restrictive measures. This affects banks as well as other financial service providers, including crypto-asset service providers.<\/p>\n\n\n\n Overall, following this sanctions package as well, you should once again carefully examine each individual transaction with a connection to Russia to determine whether it remains permissible.<\/p>\n\n\n\n We would be glad to assist you.<\/p>\n\n\n\n
Articles 3 to 3sa of Regulation (EU) No 833\/2014 introduce new export and import restrictions. The export prohibitions cover, among other things, explosives, laboratory glassware, high-performance lubricants, tractors, and lubricant additives. Import prohibitions are also established for metals, chemicals, and minerals, together with an import quota for ammonia (688,000 tonnes between 24 April 2026 and 23 April 2027). Transitional rules apply for the performance of contracts concluded before 24 April. These newly listed goods are intended to prevent the military and technological strengthening of Russia, or the development of its defence and security sector, and to rule out any strengthening of Russia’s industrial capacities.<\/p>\n\n\n\n