On 19 September 2022 the EU further amended its frequently asked questions list (FAQs) clarifying the application of articles 3g, 3i and 3j in particular of Council Regulation 833/2014.
The EU have clarified that certain goods, such as fertilizers, animal feeds, essential goods, and coal and related products, are now permitted to be transported to non-EU countries to mitigate food and energy insecurity. Also relevant services (such as financial assistance including brokering or insurance) tied to the transfer under Articles 3i and 3j of the above-listed goods to third countries via EU operators or the EU territory are now permitted.
Contrary to the position taken by the EU in August, the FAQs now make it clear that the transport of coal and certain specified goods in Annex XXI of Council Regulation 833/2014 (and related insurance) is in fact not prohibited when the goods are being carried to third countries.
Import of said goods ex Russia into EU territory remains prohibited.
For a detailed analysis of the amended EU position we refer Members to the Client Alert published earlier by UK law firm Reed Smith, available through following link:
Members may also find detailed information in circular issued by all IG Clubs – for our Member’s ease of reference we enclose hereby the link to the circular issued by North Of England:
*** In the current landscape of ever changing sanctions regulations (an 8th EU sanctions package has been issued as from October 6th) Members are recommended to contact NNPC at firstname.lastname@example.org in respect of any sanctions related issues ***