04 March 2022

UKRAINE/RUSSIA CRISIS TRADE SANCTIONS

In view of the Russian Federation’s unprovoked and unjustified military aggression against Ukraine, the European Union imposed an unprecedented number of sanctions against the Russian Federation, in addition to the Russian embargos in place since 2014.

On 23 February, the EU issued further financial and economic sanctions­ against the Russian Federation due to the Russian recognition of the Donetsk and Luhansk territories. The package included restrictions on economic relations with the non-government controlled areas of Donetsk and Luhansk oblasts, such a ban to import into the EU goods originating in the specified territories and a ban to sell, supply, transfer, or export specified goods and technology, suited for use in the telecommunications, transport, energy and oil production sectors, to any natural or legal person, entity or body in the specified territories, or for use in the specified territories.

In response to the Russian attack­ on Ukraine, a second package of measures followed on 25 February, where the major trade-related sanctions ­concerned the financial, energy and transport sectors, dual-­use goods and export controls. The third package of santions agreed on 28 February included, in addition to a ban on the overflight of EU airspace and on access to EU airports by Russian carriers, a ban on transactions with the Russian Central Bank. On 2 March, the EU excluded seven Russian banks from SWIFT, disconnecting them from the international financial system and harming their ability to operate globally.

The relevant regulations do not require any transposition into national law but apply immediately from the date of publication in the Official Journal of the European Union. All EU sanctions regulations have direct effect in all Member States of the EU, and, as such, are legally binding on all natural and legal persons in the EU. Private companies, therefore, have an obligation to ensure that they are in full compliance with these new measures. A natural or legal person who contravenes a provision of an EU sanctions regulation shall be guilty of an offence and liable to prosecution. 

European freight forwarding and logistics companies that are currently engaged in business with Russia are strongly encouraged to find out more about the new sanction measures and ensure compliance.

For more information on the measures and respective legal acts, you can visit the webpage of the EU Council.