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Since 23 February 2022, the EU has adopted new sanctions against Russia that expand the sanctions imposed in 2014 or introduce additional restrictions.
Sanctioned Persons
New Asset Freezes
On 23 February 2022, the EU designated various individuals and entities active in the political, military, banking, and media sectors:
- 351 members of the Russia State Duma who voted for the recognition of independence of the so-called Donetsk People’s Republic (DNR) and the Luhansk People’s Republic (LNR)
- Three Russian banks: Rossiya Bank, Promsvyazbank, and Vnesheconombank (VEB) — a new exception is provided to allow for the wind-down of existing relationships with those banks until 24 August 2022
- 24 individuals and entities, including (a) the decision-makers responsible for threatening Ukraine and entities financially and materially supporting, or benefiting from them; (b) those operating in the defence sector; and (c) those who engage in a disinformation war against Ukraine
On 25 February 2022, the EU designated an additional 98 individuals, including (a) Russia’s President Vladimir Putin; (b) members of the Russia National Security Council who supported Russia’s recognition of independence of the so-called DNR and LNR; (c) individuals who facilitated the Russian military aggression from Belarus; and (d) additional members of the Russia State Duma who voted for the recognition of independence of the so-called DNR and LNR.
On 28 February 2022, the EU designated an additional 26 individuals and one entity, including the closest advisers and supporters of Russia’s President Vladimir Putin.
On 2 March 2022, the EU designated an additional 22 individuals, including various representatives of the Ministry of Defence and military forces of Belarus for participating in the Russian military aggression against Ukraine.
On 9 March 2022, the EU designated an additional 160 individuals, including (a) members of the Russian Federation Council who supported Russia’s recognition of independence of the so-called DNR and LNR; and (b) various individuals (oligarchs) supporting and benefitting from the Russian Government or providing a substantial source of revenue to it, or associated with formerly designated individuals or entities.
On 15 March 2022, the EU designated an additional 15 individuals and 9 entities, including (a) various individuals (oligarchs) supporting and benefitting from the Russian Government or providing a substantial source of revenue to it; and (b) certain businesses active in the military and shipbuilding sectors. The EU has also explicitly referenced certain entities associated with these designated individuals and entities to which sanctions extend.
On 8 April 2022, the EU designated:
- 217 individuals, including (a) high-ranking officials of the Russian Government, as well as ministers and council members of the so-called DNR and LNR; (b) oligarchs and other prominent businesspeople involved in key sectors such as energy, finance, media, and defence; and (c) family members of already designated individuals
- 18 entities, including (a) four major Russian banks (i.e., Otkritie Bank, Novikombank, Sovcombank, and VTB); and (b) companies active in the transportation and defence sectors. There is a wind-down period for activities that are necessary for the termination, by 9 October 2022, of operations, contracts or other agreements, including correspondent banking relations, concluded with those banks before 8 April 2022. Such wind-down exception is available upon application for a specific license before the competent EU Member States authorities.
On 3 June 2022, the EU designated an additional 65 individuals and 18 entities, including (a) individuals reportedly involved in the atrocities committed by the Russian armed forces in Bucha and other Ukrainian towns; and (b) telecom companies, car and aircraft manufacturers, and key suppliers to Russian defence customers. An exception applies to allow EU operators to provide electronic communication services, as well as associated facilities and services necessary for the operation, maintenance, and security of such electronic communication services.
The designations entail (a) a freezing of all funds and economic resources belonging to, owned, held, or controlled by the designated individuals or entities; and (b) a prohibition to make funds or economic resources available, directly or indirectly, to or for the benefit of the designated individuals or entities. These prohibitions extend to dealings with persons that are owned or controlled by designated individuals or entities.
Prohibition of dealings with certain Russian state-owned entities
On 15 March 2022, the EU introduced a new type of prohibition to, directly or indirectly, engage in any transaction with certain state-owned entities and entities that are owned by such persons or that act on their behalf or at their direction. The targeted Russian state-owned entities currently include: OPK Oboronprom, United Aircraft Corporation, Uralvagonzavod, Rosneft, Transneft, Gazprom Neft, Almaz-Antey, Kamaz, Rostec, JSC Po Sevmash, Sovcomflot, and United Shipbuilding Corporation.
This prohibition does not apply to transactions (a) to be executed until 15 March 2022 pursuant to contracts entered into before 16 March 2022; (b) necessary for the direct or indirect import or transport of natural gas and oil, including refined petroleum products, and certain metals and ores into the EU, the European Economic Area, Switzerland, or the Western Balkans; (c) related to energy projects outside Russia where the targeted Russian state-owned entity is a minority shareholder; or (d) transactions related to the purchase, import, or transport into the EU of coal and other solid fossil fuels until 10 August 2022.
On 3 June 2022, the EU clarified that this prohibition does not apply to (a) the reception of payments due by these targeted Russian state-owned entities under contracts performed before 15 May 2022; (b) transactions, including sales, strictly necessary for the wind-down by 5 September 2022 of a joint venture or similar legal arrangement concluded before 16 March 2022; and (c) transactions related to the provision of electronic communication services, data centre services, services and equipment necessary for their operation, maintenance, security, and call centre services.
Trade Ban on the Donetsk and Luhansk Regions
On 23 February 2022, the EU adopted a trade ban against the non-government-controlled areas of DNR and LNR (DNR and LNR Areas), similar to the ban in place for Crimea since 2014:
- Import ban on all products originating from the DNR and LNR Areas
- Export ban on specifically listed products (e.g., products relating to transport, telecommunications, energy, and oil & gas) to the DNR and LNR Areas
- Prohibition to provide certain services (i.e., financing, financial assistance, insurance, and insurance-related services) in relation to those products
- Prohibition of new investments (e.g., real estate, joint-venture, etc.) in the DNR and LNR Areas, and prohibition of provision of certain financial services (financing, loan, credit, and investment services) in relation to those investments
- Prohibition to provide services relating to tourism activities in the DNR and LNR Areas
Sectoral Sanctions and Sovereign Debt Restrictions
Trade restrictions (new Russia-related export controls)
On 25 February 2022, the EU adopted additional sectoral sanctions affecting a wide range of trade dealings with Russia and Russian persons:
- Prohibition to, directly or indirectly, (a) sell, supply, transfer, or export to or for use in Russia dual-use goods and technology listed on Annex I of EU Dual-Use Regulation 2021/821; and (b) provide related services, including, but not limited to, technical assistance, financial assistance, and brokering services
- Prohibition to, directly or indirectly, (a) sell, supply, transfer, or export to or for use in Russia certain goods and technology that might contribute to Russia’s technological enhancement of its defence and security sector (e.g., microprocessors, storage integrated circuits, electronic beam systems, digital computers, telecom and radio equipment, information security software and equipment, semiconductor lasers, diesel engines, and tractors); and (b) provide related services, including, but not limited to, technical assistance, financial assistance, and brokering services; the list of restricted goods and technology was further expanded on 8 April and 3 June 2022
- Prohibition to, directly or indirectly, (a) sell, supply, transfer, or export to or for use in Russia certain goods and technologies for use in the aviation and space industry; and (b) provide related services, including, but not limited to, technical assistance, financial assistance, brokering services, insurance and reinsurance, as well as certain services (e.g., overhauling, inspection, replacement, modification, and defect rectification) for aircraft and components thereof; the list of restricted goods and technologies was further expanded on 8 April 2022
- Prohibition to provide public financing or financial assistance for trade with, or investment in, Russia
The EU provided for various exceptions to allow certain categories of trade:
- Humanitarian purposes, health emergencies, medical and pharmaceutical purposes, temporary export for use by news media, software updates, consumer communication devices, cybersecurity and information security purposes for non-governmental bodies, EU-Russia cooperation in civilian matters, intergovernmental cooperation in space programmes, civil nuclear operations and cooperation, maritime safety, civilian telecommunication networks (including the provision of internet services), exclusive use for Russian entities owned or controlled by EU or partner country parents, and diplomatic use
- For obligations concluded before 26 February 2022 (exemption must be requested before 1 May 2022)
EU Member States will not grant any exemptions for Russian military end-users, military end-use in Russia, and aviation or space industry use. The EU provided a list of 64 Russian military end-users, comprising almost all Russian defence, military aviation, aerospace, shipbuilding companies, governmental research institutes, defence, and intelligence services. The list of military end-users was further expanded on 15 March and then again on 3 June 2022.
On 9 March 2022, the EU introduced additional sectoral sanctions targeting the maritime sector, including a prohibition to, directly or indirectly, (a) sell, supply, transfer, or export to or for use in Russia, maritime navigation goods and technology (including navigation and radio-communication equipment); and (b) provide related services, including, but not limited to, technical assistance, financial assistance, and brokering services. Certain exceptions apply to allow certain categories of trade, including humanitarian purposes, health emergencies, the prevention or mitigation of health or environment disasters, or maritime safety.
On 15 March 2022, the EU introduced further trade restrictions, including:
- Prohibition to, directly or indirectly, import, purchase, transport, or provide services relating to, certain iron and steel products originating in or exported from Russia into the EU; the list of restricted iron and steel products was further expanded on 8 April 2022
- Prohibition to, directly or indirectly, sell, supply, transfer, or export certain luxury goods to or for use in Russia (e.g., caviar, truffles, wines, carpets, cutlery, watches, jewellery, certain electronic items for domestic use)
Certain exceptions apply to allow certain categories of trade, including transactions that are (a) necessary to import and transport fossil fuels into the EU; and (b) necessary to prevent or mitigate health or environmental disasters, or maritime safety. Wind-down periods are provided to allow for the execution of certain contracts concluded before 16 March 2022.
On 8 April 2022, the EU introduced further trade restrictions, including:
- Prohibition to, directly or indirectly, (a) purchase, import, or transfer into the EU certain goods originating or exported from Russia (e.g., seafood, caviar, cement, fertilizers, glass); and (b) provide related services, including but not limited to, technical assistance, financial assistance, and brokering services; the list of restricted goods was further expanded on 3 June 2022
- Prohibition to, directly or indirectly, (a) sell, supply, transfer, or export to or for use in Russia certain goods and technology that might contribute to Russia’s industrial enhancement (e.g., tubes, pipes, rubber, tyres, pulps); and (b) provide related services, including but not limited to, technical assistance, financial assistance, and brokering services
- Prohibition for any road transport undertaking established in Russia to transport, including in transit, goods by road within the EU
- Prohibition to provide access to EU ports after 16 April 2022 to any vessel registered under the flag of Russia (including vessels that have changed their Russian flag or their registration to the flag or register of any other country after 24 February 2022)
Certain exceptions apply to the prohibitions on road transport and vessels to allow certain categories of transport, including for humanitarian purposes or for purchase, import, or transport into the EU of, among others, natural gas and oil, nuclear fuel, medical and pharmaceutical products, and agricultural and food products. In addition, contracts concluded before 9 April 2022 in relation to trade in coal and other fossil fuels, or goods and technology that might contribute to Russia’s industrial enhancement, as well as ancillary contracts necessary for their execution, may be executed until 10 July 2022.
Financial restrictions
On 23 February 2022, the EU extended existing financial restrictions against certain major Russian banks to additional Russian government parties, effectively impairing the ability of Russia to access EU capital and financial markets:
- Prohibition on dealings with transferable securities and money-market instruments issued after 9 March 2022 (regardless of their maturity date) by Russia, its government, the Central Bank of Russia, and entities acting on behalf, or at the direction, of the Central Bank of Russia (all referred to as Covered Parties 1)
- Prohibition to provide investment services in relation to those transferable securities and money-market instruments issued after 9 March 2022 (regardless of their maturity date) by Covered Parties 1
- Prohibition to extend new loans and credit (regardless of their maturity date) to Covered Parties 1 after 23 February 2022
Covered Parties 1 currently include: Russia and its government, the Central Bank of Russia, and any legal person, entity, or body acting on behalf or at the direction of the Central Bank of Russia.
On 25 February 2022, the EU adopted additional sectoral sanctions affecting a wide range of financial dealings with Russia and Russian persons:
- Prohibition on dealings with transferable securities and money-market instruments issued after 12 April 2022 (regardless of their maturity date) by (a) certain major credit institutions or other government-controlled institutions; (b) Russian operators that are government-controlled and where Russia, its government, or the Russian Central Bank have the right to participate in profits or hold substantial economic relationships; (c) Russian operators engaged in military equipment, services, or crude oil or petroleum; and (d) operators directly or indirectly owned for more than 50% by or acting on behalf of, or at the direction of, any of the foregoing parties (all referred to as Covered Parties 2)
- Prohibition to provide investment services in relation to those transferable securities and money-market instruments issued after 12 April 2022 (regardless of their maturity date) by Covered Parties 2
- Prohibition to extend new loans and credit (regardless of their maturity date) to Covered Parties 2 after 26 February 2022
- Prohibition to list and provide services as of 12 April 2022 on trading venues registered or recognised in the EU for the transferable securities of operators established in Russia that have over 50% public ownership
- Prohibition to accept deposits exceeding EUR 100,000 in the aggregate per credit institution from Russian nationals, residents, or operators established in Russia
- Mandatory reporting by 27 May 2022 by EU credit institutions to EU competent authorities of deposits exceeding EUR 100,000 held by Russian nationals, residents, or operators established in Russia, and subsequent reporting every year
- Mandatory reporting by 27 May 2022 by EU credit institutions to EU competent authorities of deposits exceeding EUR 100,000 held by Russian nationals residing in Russia who have acquired the citizenship of a Member State or residence rights in an EU Member State through investor citizenship or residence schemes (golden passports)
- Prohibition on EU central securities depositories to provide services for transferable securities issued after 12 April 2022 (regardless of their maturity) to Russian nationals, residents, or operators established in Russia
- Prohibition to sell euro-denominated transferable securities issued after 12 April 2022 (regardless of their maturity) or units in collective investment undertakings providing exposure to such securities to Russian nationals, residents, or operators established in Russia
Covered Parties 2 currently include: Sberbank; VTB Bank; Gazprombank; VEB; Rosselkhozbank; Alfa-Bank; Bank Otkritie; Rossiya Bank; Promsvyazbank; OPK Oboronprom; United Aircraft Corporation; UralVagonZavod; Rosneft; Transneft; Gazprom Neft; Almaz-Antey; Kamaz; Novorossiysk Commercial Sea Port; Rostec (Russian Technologies State Corporation); Russian Railways; JSC PO Sevmash; Sovcomflot; and United Shipbuilding Corporation.
On 28 February 2022, the EU imposed a prohibition on transactions related to the management of reserves or assets of Central Bank of Russia, including transactions with persons acting on its behalf, or at its direction, such as the Russian National Wealth Fund. EU competent authorities may authorise transactions “strictly necessary to ensure the financial stability” of the EU or the EU Member State concerned.
On 2 March 2022, the EU introduced further restrictions, including:
- Prohibition, as of 12 March 2022, to provide specialised financial messaging services used to exchange financial data (i.e., SWIFT) to certain Russian banks and entities established in Russia that they own, directly or indirectly, for more than 50%. The list of excluded banks includes: Bank Otkritie; Novikombank; Promsvyazbank; Bank Rossiya; Sovcombank; VNESHECONOMBANK (VEB); and VTB Bank. On 3 June 2022, the list was expanded to cover, as of 14 June 2022: Sberbank; Credit Bank of Moscow; Joint Stock Company Russian Agricultural Bank; and JSC Rosselkhozbank
- Prohibition to sell, supply, transfer, or export euro-denominated banknotes (i) to Russia; (ii) to any person in Russia, including the Russian Government and the Central Bank of Russia; or (iii) for use in Russia
- Prohibition to invest, participate, or otherwise contribute to projects co-financed by the Russian Direct Investment Fund
On 15 March 2022, the EU introduced further financial restrictions, including:
- Prohibition to acquire any new or to extend any existing participation in, create any new joint venture with, grant or be part of any arrangement to grant any new loan or credit or otherwise provide financing to, or provide investment services in connection thereto, any operators in the energy sector in Russia, except if (a) concerning an operator that is owned by an EU business; or (b) necessary for ensuring critical energy supply in the EU or the transport of fossil fuels to the EU
- Prohibition, as of 15 April 2022, to provide credit-rating services, as well as to provide access to subscription services in relation to credit-rating activities, to Russian nationals, residents, or operators established in Russia
On 8 April 2022, the EU introduced further restrictions, including:
- Prohibition to award or continue the execution of certain public or concession contracts to or with (i) Russian nationals or operators established in Russia; (ii) operators directly or indirectly owned for more than 50% by persons under (i); or (iii) operators acting on behalf or at the direction of persons under (i) or (ii)
- Prohibition to provide, directly or indirectly, support, including financing and financial assistance or any other benefit, under certain EU, Euratom or Member State programmes or contracts to operators established in Russia with over 50% public ownership or public control
Certain exceptions apply to allow public or concession contracts or support under EU, Euratom or Member State programmes or contracts relating to, among others, radioactive waste management, fuel supply, civil nuclear facilities, environmental radiation monitoring, or intergovernmental cooperation in space programmes.
The EU further prohibited to (a) register; (b) provide a registered office, business, or administrative address to; (c) provide management services to; or (d) act or arrange for others to act as trustee, nominee shareholder, director, secretary, or a similar position for a trust or any similar legal arrangement having as a trustor or a beneficiary (i) Russian nationals, residents, or operators established in Russia; (ii) operators directly or indirectly owned for more than 50% by persons under (i); (iii) operators controlled by persons under (i) or (ii); or (iv) operators acting on behalf or at the direction of persons under (i) to (iii). On 3 June 2022, the EU clarified that the restriction in point (d) will apply as of 5 July, and that operations necessary to terminate contracts concluded before 9 April 2022 will be allowed until 5 July 2022 (with the possibility for parties to seek an authorisation to continue such operations until 5 September 2022).
The EU also expanded some of the existing restrictions introduced since 25 February 2022 (see above), including by extending the prohibitions on deposits and euro-denominated transferable securities to (a) provide crypto-asset wallet, account, or custody services to Russian nationals, residents, or operators established in Russia if the crypto-assets exceed EUR 10,000 per wallet, account, or custody provider; (b) sell transferable securities denominated in any official currency of a Member State issued after 12 April 2022 or units in collective investment undertakings providing exposure to such securities; and (c) sell, supply, transfer, or export banknotes denominated in any official currency of a Member State.
On 3 June 2022, the EU prohibited to, directly or indirectly, provide accounting, auditing, bookkeeping, tax consulting services, business and management consulting, or public relations services to the Russian Government or persons established in Russia. The prohibition does not apply to the provision of covered services (a) intended for the exclusive use of persons established in Russia that are owned, or solely or jointly controlled, by an entity or other legal person incorporated or constituted in the EU; (b) necessary for the termination by 5 July 2022 of contracts concluded before 4 June 2022, or of ancillary contracts necessary for the execution of such contracts; or (c) necessary for the exercise of the right of defence in judicial proceedings or the right to an effective legal remedy.
Aviation restrictions
On 28 February 2022, the EU imposed a prohibition on aircrafts operated by Russian air carriers, Russian-registered aircrafts, and non-Russian-registered aircrafts that are owned, chartered, or controlled by a Russian person, to land in, take off from, or overfly the territory of the EU, except in case of emergency landing or overflight. A network manager is appointed to coordinate and ensure effective implementation of this prohibition across the EU.
Broadcasting restrictions
On 2 March 2022, the EU introduced a prohibition to broadcast, or to enable, facilitate or otherwise contribute to broadcast, any content by certain Russian media companies, including through transmission or distribution by any means, such as cable, satellite, IP-TV, internet service providers, or internet video-sharing platforms or applications, whether new or pre-installed. The EU further suspended all broadcasting licences, authorisations, transmission, and distribution arrangements with such Russian media companies.
On 3 June 2022, the EU additionally prohibited to advertise products or services in any content produced or broadcast by these restricted Russian media companies.
The list of affected Russian media companies, as last expanded on 3 June 2022, includes: RT- Russia Today English; RT- Russia Today UK; RT - Russia Today Germany; RT - Russia Today France; RT- Russia Today Spanish; Sputnik; Rossiya RTR/RTR Planeta; Rossiya 24/Russia 24; and TV Centre International.
Oil and energy restrictions
On 25 February and 15 March 2022, the EU prohibited to, directly or indirectly, (a) sell, supply, transfer, or export to or for use in Russia certain goods and technologies for use in, respectively, oil refining or the energy sector; and (b) provide related services, including, but not limited to, technical assistance, financial assistance, and brokering services. The list of restricted goods and technologies for use in oil refining was further expanded on 8 April 2022.
On 8 April 2022, the EU prohibited to, directly or indirectly, (a) purchase, import, or transfer into the EU coal and other fossil fuels originating in or exported from Russia; and (b) provide related services, including but not limited to, technical assistance, financial assistance, and brokering services.
On 3 June 2022, the EU expanded the import ban to certain crude oil and petroleum products originating in or exported from Russia, primarily targeting seaborne crude oil and petroleum. Specifically, it is prohibited to, directly or indirectly:
- Purchase, import, or transfer into the EU crude oil and petroleum products originating in or exported from Russia, and provide related services, including but not limited to, technical assistance, financial assistance, and brokering services
- Provide technical assistance, brokering services, financing, or financial assistance, related to the transport, including through ship-to-ship transfers, to third countries of crude oil or petroleum products originating in or exported from Russia
Various exceptions may apply to allow, among others, for (a) the execution until 5 December 2022 of contracts concluded before 4 June 2022, as well as ancillary contracts necessary for their execution; (b) the execution until 5 December 2022 of one-off transactions relating to specified products for near term delivery; (c) transactions relating to products that originate in a third country, are owned by a non-Russian company, and are only being loaded in, departing from, or transiting through Russia; and (d) purchases required to meet essential needs or humanitarian projects in Russia, or in other extraordinary circumstances. Additional exceptions may apply as regards certain EU Member States. Furthermore, crude oil delivered by pipeline from Russia into the EU is generally excluded from this prohibition.
Sanctions Against Belarus
On 2 March 2022, the EU adopted new sanctions against Belarus in response to Belarus’ involvement in the Russian aggression against Ukraine. These sanctions entail broad trade restrictions:
- Prohibition to, directly or indirectly, (a) sell, supply, transfer, or export to or for use in Belarus dual-use goods and technology listed on Annex I of EU Dual-Use Regulation 2021/821; and (b) provide related services, including, but not limited to, technical assistance, financial assistance, and brokering services
- Prohibition to, directly or indirectly, (a) sell, supply, transfer, or export to or for use in Belarus certain goods and technology that might contribute to Belarus’ technological enhancement of its defence and security sector (e.g., microprocessors, storage integrated circuits, electronic beam systems, digital computers, telecom and radio equipment, information security software and equipment, semiconductor lasers, diesel engines, and tractors), as well as certain machinery (e.g., turbines, engines, pumps, and centrifuges); and (b) provide related services, including, but not limited to, technical assistance, financial assistance, and brokering services
- Prohibition to, directly or indirectly, (a) import certain wood, cement, iron and steel, and rubber products originating in or exported from Belarus; and (b) provide related services, including, but not limited to, technical assistance, financial assistance, and brokering services
The EU provided for various exceptions to allow certain categories of exports: humanitarian purposes, health emergencies, medical and pharmaceutical purposes, temporary export for use by news media, software updates, consumer communication devices, cybersecurity and information security purposes for non-governmental bodies, EU-Belarus cooperation in civilian matters, intergovernmental cooperation in space programmes, civil nuclear operations and cooperation, maritime safety, civilian telecommunication networks (including the provision of internet services), exclusive use for Belarusian entities owned or controlled by EU or partner country parents, and diplomatic use.
Contracts concluded before the imposition of these sanctions can be performed subject to certain conditions: (a) contracts for the sale and export of restricted goods and technology can be performed if concluded before 3 March 2022 and exemption is requested before 1 May 2022; and (b) contracts for the import of restricted goods can be performed until 4 June 2022 if concluded before 2 March 2022.
EU Member States will not grant any exemptions for goods and technology intended for the Belarus Ministry of Defence and, as of 3 June 2022, other 24 restricted military end-users.
On 9 March 2022, the EU adopted additional sectoral sanctions affecting a wide range of financial dealings with Belarus and Belarusian persons:
- Prohibition, as of 20 March 2022, to provide specialised financial messaging services used to exchange financial data (i.e., SWIFT) to certain Belarusian banks and entities they own, directly or indirectly, for more than 50%. The list of excluded banks included: Belagroprombank; Bank Dabrabyt; and Development Bank of the Republic of Belarus. On 3 June 2022, the list was expanded to cover, as of 14 June 2022: Belinvestbank (Belarusian Bank for Development and Reconstruction)
- Prohibition on transactions related to the management of reserves or assets of the Central Bank of Belarus, including transactions with persons acting on its behalf, or at its direction. EU competent authorities may authorise transactions “strictly necessary to ensure the financial stability” of the EU or the EU Member State concerned
- Prohibition to list and provide services as of 12 April 2022 on trading venues registered or recognised in the EU for the transferable securities of operators established in Belarus that have over 50% public ownership
- Prohibition to provide public financing or financial assistance for trade with, or investment in, Belarus
- Prohibition to accept deposits exceeding EUR 100,000 in the aggregate per credit institution from Belarusian nationals or residents or operators established in Belarus
- Mandatory reporting by 27 May 2022 by EU credit institutions to EU competent authorities of deposits exceeding EUR 100,000 held by Belarusian nationals, residents, or operators established in Belarus, and subsequent reporting every year
- Mandatory reporting by 27 May 2022 by EU credit institutions to EU competent authorities of deposits exceeding EUR 100,000 held by Belarusian nationals residing in Belarus who have acquired the citizenship of a Member State or residence rights in an EU Member State through investor citizenship or residence schemes (golden passports)
- Prohibition on EU central securities depositories to provide services for transferable securities issued after 12 April 2022 (regardless their maturity) to Belarusian nationals or residents or operators established in Belarus
- Prohibition to sell euro-denominated transferable securities issued after 12 April 2022 (regardless their maturity) or units in collective investment undertakings providing exposure to such securities to Belarusian nationals or residents or operators established in Belarus
- Prohibition to sell, supply, transfer, or export euro-denominated banknotes (i) to Belarus; (ii) to any person in Belarus, including the Belarusian Government and the Central Bank of Belarus; or (iii) for use in Belarus
On 8 April 2022, the EU further prohibited any road transport undertaking established in Belarus to transport, including in transit, goods by road within the EU. Certain exceptions apply to allow certain categories of transport, including for humanitarian purposes or for purchase, import, or transport into the EU of, among others, natural gas and oil, medical and pharmaceutical products, and agricultural and food products.