Germany: EU authorized new sanctions against Russia

Published on Jul 23, 2023

In response to the Russian Federation’s activities targeting Ukraine and the recognition of Luhansk/Donetsk as independent regions, EU foreign ministers have authorized eleven packages of sanctions. The packages include several regulations limiting Russia’s access to the capital market. Moreover, they include financial sanctions against certain individuals and companies as well as export bans and implement a price cap on Russian crude oil and certain oil products. Violations are subject to severe penalties.

In the following, we provide a general overview of the sanctions regime and explain what companies need to do now.

I. New Sanctions

First package of Sanctions

1. Restrictions of the capital market (Regulation (EU) 2022/262)

EU Official Journal Nr. L 42I, 02-23-2022, P. 74-76: Regulation(EU) 2022/262

  • Trading of securities and money market instruments issued after March 9, 2022 by Russia and its government, the Central Bank of Russia or any legal person, entity or body acting on behalf of or under the direction of the Central Bank of Russia, is prohibited. The prohibition includes securities services or auxiliary services in connection with the issuance of these securities.
  • Any participation in lending or borrowing money to legal persons, entities, or bodies referred above after February 23, 2022, is forbidden.

2. Financial sanctions against natural persons and companies (Regulation (EU) 2022/260, 2022/261 and extended by the following packages of sanctions)

EU Official Journal Nr. L 42I, 02-23-2022, P. 15-73: Regulation (EU) 2022/260; EU Official Journal Nr. L 42I, 02-23-2022, P. 3-14: Regulation (EU) 2022/261; EU Official Journal Nr. L 53, 02-25-2022, S. 1-44: Regulation (EU) 2022/332; EU Official Journal Nr. L 58, 02-28-2022, P.1-18: Regulation (EU) 2022/336; EU Official Journal Nr. L 66, 03-02-2022, P. 1-13: Regulation (EU) 2022/353; EU Official Journal Nr. L 80, 09-03-2022, P. 1-30: Regulation (EU) 2022/396; EU Official Journal Nr. L 84, 03-11-2022, P. 2-17: Regulation (EU) 2022/408; EU Official Journal Nr. L 87I, 03-13-2022, P.1-12: Regulation (EU) 2022/427

  • The approximately 350 members of the Russian Parliament who voted in favor of the Russian recognition of Luhansk/Donetsk as sovereign states are now included in Regulation (EU) 269/2014. Thereby, all of their funds and economic resources are frozen.
  • It is prohibited to provide funds or economic resources, directly or indirectly, to the listed persons. A prohibited provision of funds or economic resources may also be given if the recipients or end-users are not themselves listed, but are controlled by an entity listed in Annex I.
  • The sanctions list of Regulation (EU) 269/2014 includes a total number of about 950 individuals and organizations. Among them are the Russian Deputy Prime Minister Shoigu, the Minister of Defense Grigorenko the Russian state bank “Promsvyazbank” and Roman Abramovitsch.

3. Regional sanctions concerning Luhansk/Donetsk (Regulation (EU) 2022/263)

EU Official Journal Nr. L 42I, 02-23-2022, P. 77-94: Regulation EU 2022/263

  • Trade between the EU and Luhansk/Donetsk will be substantially limited, following the example of the trade sanctions against Crimea/Sevastopol (see 2).
  • Import of goods originating in the specified territories, as well as the direct or indirect provision of financing in connection with import, is prohibited. This does not apply to old contracts (including contracts concluded before February 23, 2022) and to goods for which Ukrainian authorities have verified the origin of production in accordance with EU law requirements.
  • Ban on investment: The acquisition or increase of interest in the ownership of real estate as well as the establishment of joint ventures or the associated provision of investment services in Luhansk/Donetsk is prohibited.
  • Ban on export of goods and technologies specified in Annex II, particularly those relating to key sectors such as transport, energy and communication.

Second package of Sanctions

On February 24, the EU foreign ministers decided to impose additional sanctions (Regulation (EU) 2022/328).

  • Russian banks are to be banned from borrowing and lending money in the EU in the future.
  • Shares in Russian state-owned companies may no longer be traded.
  • The acceptance of deposits from Russian citizens or residents exceeding certain values and the sale of securities denominated in euro to Russian customers is prohibited.
  • The supply of spare parts and other technology to the Russian transport sectors will be cut off.
  • There are additional export restrictions on dual-use goods and technologies.
  • The same applies to goods and technologies that could help improve Russia’s defense and security sector.
  • Sale, supply and export of certain goods and technologies for oil refining is prohibited.
  • Restrictions on visa policy: Entry opportunities for Russian diplomats and businessmen will be restricted (EU Official Journal Nr. L 54, 02-25-2022, P.1-3: Council Decision (EU) 2022/333).
  • Irrespective of the authorized sanctions by the EU, the German government has halted the authorization process for the “Nord Stream 2” pipeline project.

Third package of Sanctions

In response to continued attacks by Russian forces in Ukraine, the United States, France, Canada, Italy, the United Kingdom, the EU Commission and Germany agreed on further financial sanctions against Russia on February 26, 2022.

  • Exclusion of certain banks from “Swift”

The following Russian banks are excluded from the international payment service system “Swift”: Bank Otkritie, Novikombank, Promsvyazbank, Bank Rossiya, Sovcombank, Vnesheconombank (VEB), VTB Bank. These institutions shall be excluded from international financial flows and their global operations shall be restricted. No euro banknotes may be delivered to Russia (EU Official Journal Nr. L 63, 28-02-2022, P.1-4: Regulation (EU) 2022/345).

  • Restrictions on Russian Central Bank

It was decided to further restrict the Russian Central Bank’s ability to support the ruble’s exchange rate with international financial transactions. There is a ban on transactions related to the management of reserves and assets of the Central Bank of Russia, as well as on transactions with legal persons or entities acting on behalf of or at the direction of the Central Bank of Russia (e.g. the Russian National Wealth Fund) (EU Official Journal, Nr. L 57, 28-02-2022, P. 1-3: Regulation (EU) 2022/334; EU Official Journal Nr. L 81, 09-03-2022, P. 1-7: Regulation 2022/394).

  • Establishment of a Task Force

A task force with representatives from the U.S. and the EU will be established to ensure a quick implementation of the sanctions and to freeze the assets of sanctioned individuals, their families and companies.

  • It is prohibited to enter the airspace of the EU for Russian aircrafts (EU Official Letter Nr. L 57, 02-28-2022, P. 1-3: Regulation (EU) 2022/334).
  • Broadcasters are not permitted to broadcast Russian media such as Russia Today (EU Official Letter Nr. L 65, 03-02.2022, P. 1-4, Regulation (EU) 2022/350).
  • Sanctions on the maritime sector: Maritime goods and technology listed in Annex XVI, whether originating in the EU or not, may not be supplied or exported, directly or indirectly, to natural or legal persons in Russia. In addition, the list of legal persons and entities subject to restrictions on financing through loans, transferable securities and money market instruments was extended to the maritime sector (EU Official Journal Nr. L 81, 09-03-2022, P. 1-7: Regulation 2022/394).

Fourth package of Sanctions

The EU has agreed on a fourth package of sanctions against Russia (EU Official Journal Nr. L 87I, 03-15-2022, P. 13-43: Regulation (EU) 2022/428).

  • Russia’s so called most-favored-nation (MFN) status in EU markets will be withdrawn. Thereby, important advantages that Russia enjoys as a WTO member will be cancelled. That would allow member states to unilaterally impose tariffs and other trade barriers against Russia. Under the WTO agreement, countries would normally not be allowed to be discriminatory between their trading partners.
  • The Russian state and leading elites will be blocked from trading cryptocurrencies in order to prevent the circumvention of already existing sanctions (Press release of the President of the Commission 03-11-2022).
  • Export of luxury goods from the EU to Russia will be banned. These include wines, beers, cigarettes, perfumes, clothing, jewelry etc. (Art. 3h Regulation (EU) 833/2014, as last amended by Regulation (EU) 2022/428).
  • Import of essential goods from the iron and steel sector as listed in Annex XVIII from Russia to the EU will be stopped. It is prohibited to directly or indirectly provide technical assistance, brokering services, financing or financial assistance, including financial derivatives and insurance and reinsurance, related to the specified goods (Art. 3g Regulation (EU) 833/2014, as last amended by Regulation (EU) 2022/428).
  • It is agreed upon a major ban on new European investment in Russia’s energy sector. Export of equipment, technologies and services for the energy sector in Russia is not allowed (Art. 3a Regulation (EU) 833/2014, as last amended by Regulation (EU) 2022/428).
  • The Russian state and Russian companies will no longer be allowed to be rated by EU rating agencies. Access to subscription services in connection with rating activities may also not be granted (Art. 5j Regulation (EU) 833/2014, as last amended by Regulation (EU) 2022/428).
  • Transactions with Russian state owned enterprises listed in Annex XIX are prohibited. This includes those enterprises which are under public control or in public hand by more than 50%, or in which Russia and its government or the Central Bank of Russia has the right to participate in profits or have other significant economic relations with or enterprises outside the Union in which more than 50% of the shares are held directly or indirectly by one of the organizations listed in Annex XIX (Art. 5aa Regulation (EU) 833/2014, as last amended by Regulation (EU) 2022/428).

Fifth package of Sanctions

The EU has adopted a fifth package sanctions against Russia with the following measures. This fifth package includes six pillars (EU Official Journal Nr. L 111, 04-08-2022, P. 1-66: Regulation (EU) 2022/576):

  • Ban on imports of coal from Russia worth EUR 4 billion annually (Art. 3j Regulation (EU) 833/2014, as last amended by Regulation (EU) 2022/576).
  • Complete ban on transactions against four Russian banks, including Russia's second largest bank VTB.
  • Ban on Russian ships and Russian-operated vessels from calling at EU ports (exceptions include certain essential goods such as agricultural and food products, humanitarian aid, and energy) and ban on Russian and Belarusian road transport companies (Art. 3ea Regulation (EU) 833/2014, as last amended by Regulation (EU) 2022/576).
  • Targeted export bans of EUR 10 billion on additional certain goods and technologies to Russia (e.g., quantum computers, advanced semiconductors, sensitive machinery, and transportation equipment) to weaken Russia's technological base and industrial capacity (Annex VII Regulation (EU) 833/2014, as last amended by Regulation (EU) 2022/576).
  • Further ban on imports of timber, cement, seafood, and alcoholic beverages (vodka)(Art. 3i Regulation (EU) 833/2014, as last amended by Regulation (EU) 2022/576).
  • A ban on the participation of Russian companies in the awarding of public contracts in EU member states and an exclusion of any financial support from the Union or its member states for Russian public institutions (Art. 5k Regulation (EU) 833/2014, as last amended by Regulation (EU) 2022/576).

Finally, additional natural and legal persons are also added to the European sanctions list. These are thus subject to the so-called ban on provision (see comments above).

Sixth package of Sanctions

On the night of May 30-31, 2022, the European Council agreed on a sixth package of sanctions against Russia, including the following measures (EU Official Journal Nr. L 153, 06-03-2022, P. 53-74: Regulation (EU) 2022/879):

  • Complete ban on imports of Russian oil (crude oil and petroleum products) by sea, which accounts for about two thirds of Russian deliveries to the EU. Imports via pipelines remain possible (especially at the insistence of Hungary), but Germany and other states have already announced that they will no longer import any oil at all from Russia by the end of the year, so imports are likely to fall by up to 90 percent. The import ban is expected to take effect within the next six months (Art. 3m, 3n Regulation (EU) 833/2014, as last amended by Regulation (EU) 2022/ 879).
  • Asset freezes and travel bans against other Russian companies and individuals accused of war crimes in Bucha (Art. 2, Annex I Regulation (EU) 269/2014, as last amended by Implementing Regulation (EU) 2022/878).
  • Swift exclusion of Russia's largest bank (Sberbank) (Art. 5h, Annex XIV Regulation (EU) 833/2014, as last amended by Regulation (EU) 2022/879).
  • Ban on three major Russian state broadcasters from distributing content in the EU (Art. 2f, Annex XV Regulation (EU) 833/2014, as last amended by Regulation (EU) 2022/879).
  • Export control restrictions on advanced technologies to additional military-industrial establishments (Art. 3i, Annex XXI Regulation (EU) 833/2014, as last amended by Regulation (EU) 2022/879).

Seventh package of Sanctions

On July 21, 2022, the regulation regarding the seventh package of sanctions was adopted. The sanctions became effective on July 22, 2022 and include the following measures (EU Official Journal Nr. L 193, 07-21-2022, P. 1-132: Regulation (EU) 2022/1269):

  • Ban on imports of gold originating in Russia under Annex XXVI and ban on remarketing and purchase of processed Russian gold. Also prohibition of technical assistance in connection with such goods. Exception applies to natural persons from the EU and their accompanying immediate family members for personal use (Art. 3o, Annex XXVI Regulation (EU) 833/2014, as last amended by Regulation (EU) 2022/1269).
  • Ships sailing under the Russian flag are now also prohibited from accessing sluices in the EU territory. They are now only allowed to use sluices to leave the EU territory. Possibility of derogation if access for unloading is necessary for the completion of a renewable energy project in the Union (Art. 3ea Regulation (EU) 833/2014, as last amended by Regulation (EU) 2022/1269).
  • New exemption possibility of goods according to Art. 3k / Annex XXIII for medical or pharmaceutical purposes as long as there are no sufficient reasons for a military end-use. Authorization by the competent authority of the member state is required (Art. 3k Regulation (EU) 833/2014, as last amended by Regulation (EU) 2022/1269).
  • Adjustment of capital market and financial-related sanctions: Prohibition on accepting deposits in excess of Euro 100,000 also from legal entities established outside the Union, more than 50% of whose shares are held directly or indirectly by Russian nationals or natural persons resident in Russia (Art. 5b, 5c Regulation (EU) 833/2014, as last amended by Regulation (EU) 2022/1269).
  • Inclusion of further goods in Annexes VII (Art. 2a Regulation (EU) 833/2014) and Annex XXIII (Art. 3k Regulation (EU) 833/2014)

Eighth package of Sanctions

In response to Russia’s recent actions to destabilize Ukraine, European Council passed it eighth package of sanctions on October 6, 2022, extending current sanctions and implementing new ones. In particular, they take Russia’s further aggression against Ukraine, the organization of illegal sham 'referenda' in the parts of the Donetsk, Kherson, Luhansk and Zaporizhzhia regions that are currently illegally occupied by Russia, the illegal annexation of those Ukrainian regions by Russia, as well as the mobilization in Russia and its repeated threat to use weapons of mass destruction into consideration (EU Official Journal Nr. LI 259/3, 06-10-2022, P. 3-75: Regulation (EU) 2022/1904):

  • Extension of the list of restricted items regarding chemicals, semiconductors, electronic components and substances falling under Regulation (EU) 2019/125, which could be used for capital punishment, torture or other cruel, inhuman or degrading treatment or punishment (Annex VII Regulation (EU) 833/2014, as last amended by Regulation (EU) 2022/1904).
  • Ban on the sale, supply, transfer or export of firearms, their parts and essential
    components and ammunition covered by Regulation (EU) No 258/2012.
  • Extension of the import ban on steel products that either originate in Russia or have been exported from it in order to reduce Russian industrial capacities (Art. 3g, Annex XVII; Annex XXI, XXIII Regulation (EU) 833/2014, as last amended by Regulation (EU) 2022/1904).
  • Extension of restrictions on the sale, supply, transfer and export of additional goods used in the aviation sector (Annex XI Regulation (EU) 833/2014, as last amended by Regulation (EU) 2022/1904).
  • Complete ban on imports and transfers of Russian coal products (Art. 3j, Annex XXII Regulation (EU) 833/2014, as last amended by Regulation (EU) 2022/1904).
  • Implementation of a price cap on Russian crude oil and certain oil products; ban of maritime transport of such goods to third countries in case the third country purchased Russian crude oil or petroleum at a price above the price cap (Art. 3n, Annex XXVIII Regulation (EU) 833/2014, as last amended by Regulation (EU) 2022/1904).
  • Port access and lock ban to vessels certified by the Russian Maritime Register of Shipping (Art. 3ea Regulation (EU) 833/2014, as last amended by Regulation (EU) 2022/1904).
  • Ban on Union nationals to hold any posts on the governing bodies of certain Russian State owned or controlled legal persons, entities or bodies: Also called “Lex Schröder” (Art. 5aa Regulation (EU) 833/2014, as last amended by Regulation (EU) 2022/1904).
  • Complete ban on the provision of crypto-asset wallet, account or custody services to Russian persons and residents (Art. 5b Regulation (EU) 833/2014, as last amended by Regulation (EU) 2022/1904).
  • Ban on the provision of architectural and engineering services as well as of IT consultancy services and legal advisory services (Art. 5n Regulation (EU) 833/2014, as last amended by Regulation (EU) 2022/1904).

Ninth package of Sanctions

On December 16, 2022, the Regulation regarding the ninth package of sanctions was adopted. The sanctions entered into force on December 17, 2022 and include, in particular, the following measures (EU Official Journal No. L 322, 16.12.2022, p. 1-314; Regulation (EU) 2022/2474):

  • Extension of the lists of persons subject to sanctions (Annex IV Regulation (EU) 833/2014, as last amended by Regulation (EU) 2022/2474).
  • Inclusion of further goods in the lists of Annexes VII, XI, XVII and XXIII and adaptation of the exemptions
  • Extension of the prohibition of participation in relation to the mining and quarrying sector (Art. 3a para. 2 in conjunction with Art. Art. 1x Regulation (EU) 833/2014, as last amended by Regulation (EU) 2022/2474).
  • Extension of the ban on holding management positions in Russian companies (Art. 5aa Regulation (EU) 833/2014, as last amended by Regulation (EU) 2022/2474).
  • Extension of the prohibition to provide certain business services to include advertising, market and opinion research as well as product testing and technical surveillance (Art. 5n Regulation (EU) 833/2014, last amended by Regulation (EU) 2022/2474).
  • Creation of new exemption provisions on various import and export bans for the purpose of exiting the Russian market (Art. 12b Regulation (EU) 833/2014).

Tenth package of Sancations

In regards to the ongoing combating actions in Ukraine, the Council of the European Union, passed a new sanction package in form of Council Regulation (EU) No. 2023/427 dated on 25 February 2023, the content of which alternates some of the requirements first shaped in Council Regulation (EU) Nr. 833/2014. The essential renewals and adjustments are reflected as following:

  • Interdiction of transit regarding listed Dual-Use-Items, that could possibly be used regarding to development of military, technology or defense and security politics in Russia, through Russian territory; including exemption clauses that are subject to approval (Art. 2VO (EU) No. 833/2014, last modification: Council Regulation (EU) No. 2023/427)
  • Interdiction of transit regarding firearms in accordance with Council Regulation (EU) Nr. 258/2012 through Russia (Art. 2aa Council Regulation (EU) N0. 833/2014, last modification: Council regulation (EU) No. 2023/427)
  • Ban of Russian nationals and Russian residents from management positions in critical infrastructure of the European Union (Art. 50 Council Regulation (EU) No. 833/2014; last modification: Council Regulation (EU) No. 2023/427)
  • Interdiction of allocation of storage capacity for natural gas concerning Russian nationals, Russian residents or companies domiciled in Russia (Art. 5p Council Regulation (EU) No. 833/2014; last modification: Council Regulation (EU) No. 2023/427)
  • Admission of additional goods in Annex VII (High- Tech- item list)
  • Admission of additional goods in Annex XI Air-/Spacecraft (complete and compartments), material testing machines), XXI (luxury goods, chemicals, fertilizers, construction material, tools, (compartments of) machines, engines) and XXII (plants, rocks, chemicals, photography items, catalysts, tubes/ pipes, machines) such as exemption clauses for existing contracts regarding those goods
  • Admission of an exemption clause that is subject to approval regarding goods corresponding to Annex XXIII (plants, rocks, chemicals, photography items, catalysts, tubes/ pipes, machines) for personal household usage

11th package of Sancations

On 23 June 2023, the Council of the European Union passed its 11th package of sanctions against Russia (Regulation (EU) 2023/1214 amending Regulation (EU) 833/2014). The package aims to ensure that EU sanctions against Russia are better enforced and circumventions prevented. In this context, the restriction of goods deliveries to third countries is now exceptionally possible. The sanctions came into force on 24 June 2023 and include, in particular, the following measures:

  • Tackling sanctions evasion: As a last resort, when other individual measures are ineffective, the EU can restrict the sale, supply, transfer or export of certain sanctioned goods and technologies to third countries.
  • Extension of the transit ban to goods and technologies in Annex VII (Art. 2a Para. 1a). Ban on the transit of goods listed in Annex XI (aerospace industry) and Annex XX (aircraft turbine materials and fuel additives) through Russia (Art. 3c Para. 1a).
  • Addition of 87 more organizations to the list of direct supporters of Russia's military-industrial complex: they have stricter export restrictions on dual-use goods and advanced technologies. Organizations from China, Uzbekistan, the United Arab Emirates, Syria and Armenia are also affected.
  • Extension of the list of goods for export bans for electronic products, industrial goods, steel products and cars. Revision of Annex VII (goods and technologies contributing to Russia's military and technological strengthening), Annex XVII (iron and steel products), Annex XVIII (luxury goods), Annex XXI (goods bringing significant revenue to Russia) and Annex XXIII (goods contributing to the strengthening of Russia's industrial capacities).
  • Tightening of import restrictions for iron and steel products: The importer of sanctioned iron and steel products processed in a third country into the EU must prove that the intermediate goods used do not come from Russia (Art. 3g Para. 1 d).
  • Intellectual Property Restrictions: Prohibiting the sale, transfer or disclosure of intellectual property rights and trade secrets relating to sanctioned goods and technology to any person, entity or body of or for use in Russia.
  • Extension of the luxury goods embargo to include the ban on the provision of technical support (Art. 3h para. 2).
  • Inclusion of an old contract regulation for certain goods of Annex XXIII (Art. 3k para. 3, para. 3a, para. 3b)
  • Measures in the transport sector: lorries with Russian trailers or semi-trailers are prohibited from transporting goods to the EU (Article 3l, Paragraph 1a). Extension of the ban on ships entering ports and locks in the EU (Art. 3eb para. 1, Art. 3ec para. 1).
  • Expansion of the sanctions list: freezing of the assets of over 100 additional people and organizations.

Sanctions against Belarus

  • Belarussian individuals were added to the sanctions list of Regulation 269/2014. The background is participation of Belarus in Russia’s attacks on Ukraine by allowing military aggression from its territory. Among the sanctioned individuals are Belarusian politicians and members of the military (EU Official Letter Nr. 66, 03-02-2022, P. 1-13, Regulation (EU) 2022/353).
  • Already existing sanctions against Belarus were extended. The export of dual-use goods to Belarus, goods and technologies that could contribute to the military, technological and national security development of Belarus, as well as the export of machinery to Belarus is prohibited (EU Official Letter Nr. L 67, 03-03-2022, P. 1-102, Regulation (EU) 2022/355).
  • Transactions with the Central Bank of Belarus related to the management of reserves and assets, the provision of public financing for trade with Belarus and investments in Belarus and the provision of euro banknotes to Belarus or for use in Belarus are prohibited. The listing of shares of Belarusian state-owned enterprises on EU trading markets is not permitted (EU Official Journal Nr. L 82, 09-03-2022, P. 1-8: Regulation (EU) 2022/398).

2. Already existing sanctions of the EU against Russia

  • The three packages of sanctions complement the already existing EU sanctions against Russia authorized after the Crimean annexation in 2014. These sanctions include financial sanctions against Russian individuals and organizations. Funds and assets have been frozen. The provision of funds is prohibited (Regulation (EU) 269/2014).
  • There is an arms embargo: Arms may not be exported or imported. Supporting services such as financing arms projects and transport are prohibited. Certain dual-use goods are excluded from export. Furthermore, there are export restrictions on equipment and technology for oil production.
  • Russian banks that are publicly owned by more than 50% can no longer place loans or similar financial products on the EU internal market.

Finally, there are regional sanctions concerning Crimea/Sevastopol (Regulation (EU) 692/2014), including a ban on import of goods originating in Crimea/Sevastopol and a ban on export of goods and technology listed in Annex III to natural persons or legal entities in Crimea or Sevastopol.

3. To Dos’ for my company?

  • Review of responsibilities and compliance organization: Export- and sanctions control is a management issue. The responsibility for “sanctions control” within the company has to be defined in writing and has to be made public. For companies that are exporting the listed goods, the person responsible is the head of export. The other tasks and responsibilities in connection with sanctions control must be clearly assigned and announced within the company.
  • Checking all relevant business contacts for new sanctions: Checking whether there are any business contacts with the newly listed persons, companies and organizations. Use of professional screening software or based on the “consolidate list of sanctions”.
  • Review supply chains: Due to the transit bans, companies that trade in listed goods should review their supply chains / routes.
  • Identification of possible circumvention constellations: In view of the eleventh sanctions package, which focuses on preventing circumvention of sanctions, companies should also monitor business relationships with customers in third countries more closely. In particular, if there are indications / "red flags" for a possible circumvention of the sanctions (e.g. conspicuous increase in sales volumes or connections of the customer to Russia). We recommend a "risk-based" approach to sanctions compliance and will be happy to support you in the audit.
  • If necessary, termination of contracts, export transactions and payments: Depending on the result of the screening – even if doubts remain – contracts, export transactions and payments should be terminated or not executed. Seek legal advice if necessary.