Reference is made to our previous circulars regarding sanctions against Russia in response to the escalation of the conflict in Ukraine, available on the NNPC website.
On 25 February 2023, a tenth sanctions package was adopted by the European Commission. This sanctions package provides for an extension of the existing sanctions against Russia, in particular in the following areas:
- Additional persons banks are placed on the sanction list
- Additional trade and financial sanctions
- Additional EU export bans and restrictions related to exports to Russia
- Additional bans on imports from Russia into the EU
- Implementation of a new package of enforcement and anti-circumvention measures
For a detailed overview of the content of the EU sanctions package, we refer our Members to the website of the EU, available via following link:
https://ec.europa.eu/commission/presscorner/detail/en/ip_23_1185
The sanctions package provides for the addition of approximately 120 individuals and entities to the sanctions list, including Russian decision-makers, senior government officials and military leaders, and Russian-affiliated authorities in the occupied Ukrainian territories. In addition, measures are being taken against persons in Iran who are involved in the delivery of drones.
A complete overview of the sanctioned persons and entities is available through following link:
https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32023R0429&from=EN
The EU sanctions apply within the territory of the EU, to the nationals of member states, to any legal person incorporated or constituted under the law of a Member State, to any vessel falling under the jurisdiction of a members state and in respect of any business done wholly or in part within the EU.
We advise our members to perform sanction checks per voyage, party and cargo and to document their efforts as evidence of their due diligence obligation. We also recommend that our Members consider additional requirements which may be imposed by third parties (such as banks) as well as the risk that the sanctioned status of a party or cargo may change during the course of the voyage.
