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calendar_today 30 May 2023
The Council of the European Union, on June 3, 2022, formally approved the so-called “sixth package of sanctions against the Russian Federation” through the issuance of a series of Executive Regulations, concerning restrictive measures in view of the socio-economic destabilization that Ukraine is undergoing due to recent developments in the armed conflict.
The biggest news undoubtedly concerns the so-called “oil embargo”, introduced through the adoption of Regulation (EU) No. 879/2022 – which amends the previous Regulation (EU) No. 833/2014 – which stipulates that, as of June 4, 2022, it will be prohibited to import, purchase and/or transfer, directly or indirectly, crude oil or petroleum products referred to in Annex XXV of the said Regulation, originating in Russia or exported from Russia. More precisely, these are the petroleum products identified by the following CN codes:
However, these prohibitions, are met with certain exemptions and exceptions, contained and listed in’Art. 3-quaterdecies, paragraph 3, introduced by Regulation (EU) 879/2022, which can be summarized as follows:
The’list of exceptions to the so-called “oil embargo” just recalled are not exhausted here, however, the rationale behind these exceptions è to allow Member States time to be able to establish new trade relations with other potential suppliers and/or distributors of oil and oil derivatives, so as to contain, as far as possible, the potential damage arising from the loss of a major trading partner such as Russia.
The so-called “sixth sanctions package” then extended the restrictions adopted with recent regulatory actions, against:
Finally, an important novelty concerns the prohibition – introduced through the new Article 5-indecies of Regulation (EU) 879/2022 – to provide directly or indirectly, accounting, auditing, including statutory audit, or tax advisory services or administrative/management consulting or public relations services to the following entities:
Even this prohibition, however, is not è exempt from certain exceptions. The following are some exceptions contained in the’just mentioned Article 5-indecies:
In conclusion, it can certainly be said that the so-called Sixth Sanctions Package introduced by the’EU, hinges on the “process of “escalation” sanctions against the Russian Federation and which does not seem to want to stop at all.
At this stage, è it is of paramount importance for companies exporting their products to Russia, to be fully aware of what restrictions the European Union is progressively inserting through the adoption of the sanctions packages, in order to avoid the risk of incurring prohibitions imposed by the Regulations recently issued by the EU, which could result in: the blocking of the goods at customs, the seizure of the same, the’imposition of heavy administrative sanctions and possible criminal consequences.
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