Editor’s Note
This summary outlines the EU’s 14th sanctions package against Russia, adopted on June 24, 2024. The measures include an asset freeze on 116 new individuals and entities and expanded sectoral sanctions, notably an investment ban on Russian LNG projects under construction.
On 24 June 2024, the European Union (EU) adopted its 14th sanctions package directed against Russia, imposing an asset freeze against an additional 116 individuals and entities and expanding sectoral sanctions targeting key aspects of the Russian economy, including an investment ban on liquefied natural gas (LNG) projects under construction in Russia. The asset freeze restrictions and sectoral sanctions took effect on 24 June 2024.
Several new measures also make clear that EU regulators expect EU businesses to maintain a strong sanctions compliance stance:
At the same time, EU member states are now explicitly authorised to consider voluntary self-disclosures of sanctions violations as a mitigating factor in enforcement actions.
An additional 116 individuals and entities are now subject to asset freezes in the EU.
Regulation 269 was amended to provide that, in certain circumstances, EU member states may release funds that were frozen due to the involvement of a sanctioned Russian bank in a transfer of funds from Russia to the EU where the transfer was between non-sanctioned individuals or entities.
The energy-related investment ban in Regulation 833 was extended to prohibit EU persons from selling, supplying, transferring or exporting, directly or indirectly, goods and technology to Russia for construction or completion of LNG projects such as terminals and plants. These restrictions also apply to covered services for Russian LNG projects.
EU businesses are now prohibited from: (a) providing reloading or other covered services in the EU for transshipment operations involving Russian LNG; and (b) purchasing, importing or transferring, directly or indirectly, Russian LNG into terminals in the EU that are not connected to the EU interconnected natural gas system.
Regulation 833’s restrictions on the sale, supply, export and transfer of dual-use goods and technology, advanced technology items and goods that could contribute to the enhancement of Russian industrial and defence capacities have been extended to additional chemicals, plastics, vehicles parts and machinery, among other items.
The new sanctions broadened several of the existing six-digit CN code bans to cover full four-digit categories, including: chemical industry products, plastic industry products, vehicles parts (including replacement parts for trucks) and machinery and appliances. Moreover, additional items were added to the CHP items list found in Annex XL of Regulation 833.
Imports of helium originating in or exported from Russia are banned and the scope of the ban on Russian diamonds was clarified.
The EU’s flight ban has been extended to any aircraft if a Russian individual or entity effectively determines the place or time of its take-off or landing.
A ban has been imposed on the use of the System for Transfer of Financial Messages (SPFS) or any equivalent specialised financial messaging services set up by the Central Bank of Russia or the Russian State as an alternative to the international SWIFT system.
New exemptions have been created to the “no-Russia clause” requirement under Article 12g of Regulation 833 but the requirement has been extended to the sale and licensing of IP.
The road transport ban has been extended to EU road transport undertakings owned 25% or more by a Russian individual or entity. In addition, a new annex was added listing vessels that are prohibited from accessing ports and locks in the EU, among other restrictions, because they are considered to be supporting the Russian war against Ukraine.
EU companies are now required to undertake best efforts to ensure that non-EU entities that they own or control do not undermine EU sanctions.
As of 26 December 2024, EU businesses that sell, license or transfer intellectual property (IP) rights or trade secrets relating to covered CHP items to non-EU business partners will be required to contractually prohibit their non-EU business partners (and require those partners to also prohibit their sublicensees) from using such IP or trade secrets for CHP items intended for Russia.
As of 26 December 2024, EU businesses involved in commercial transactions involving CHP items will be required to implement risk assessment policies and procedures to mitigate risk of exportation of such items to or for use in Russia.
Liability under the anti-circumvention rule’s knowledge-and-intent standard has been extended to cover a situation where a person does not deliberately seek to circumvent EU sanctions but is aware that their participation in an activity may have such object or effect and accepts this possibility.