[co-author: Kacper Maksymczuk, Helka Kittila]
On 16 December 2024, the EU adopted several new sanctions measures, including its 15th package of sanctions against Russia which expands the sectoral and financial restrictions applicable to Russian persons.
The EU also adopted new sanctions targeting Belarus, Haiti, Sudan and North Korea.
Chapter 1 - Overview of the 15h sanctions package
EU Russia sanctions
The main elements of the new package include:
- extension of the wind down of the authorisation ground for the import and export of restricted items and provision of restricted professional services and software for divestment until 31 December 2025;
- addition of 52 vessels involved in circumventing sanctions by transporting warfare material and oil to the list of vessels subject to a ban on port access and services;
- introduction of the prohibition to recognise or enforce certain rulings issued by Russian courts under Article 248 of the Russian procedural code, which grants exclusive jurisdiction to Russia’s courts;
- a new authorisation ground for the release of cash balances held by EU central securities depositaries to meet legal obligations to clients;
- a new non-liability clause for the payment of interest or any other compensation by central securities depositories to the Central Bank of Russia made in good faith;
- addition of 32 military-related entities including not only Russian but also Chinese, Indian, Iranian, Hong Kong, Serbian and U.A.E. companies to the list of entities which cannot benefit from exemptions and authorisations related to exported restrictions (Annex IV);
- designation of 54 individuals and 30 entities, including civilian airline UTAIR, manufacturer of aircraft parts Aerosila, and private air transportation company Leading Charter Technologies, which are now subject to asset freezing measures. In total, as of today, 1,829 persons and 496 entities are subject to asset freezing measures under the EU Russia sanctions.
For the first time, Chinese and Hong Kong persons and entities have been subject to asset freezing measures under the EU Russia sanctions. One EU individual has also been added to the list of asset freeze measures. These new asset freeze measures include JSC Gruppa Kremniy El, a manufacturer of microelectronics and microchips and Asia Pacific Links, a Hong Kong-based company supplying microelectronic components to Russian companies.
Russian hybrid threats
Additionally, under the new legal framework to respond to Russia’s destabilising activities against the EU organisations and third countries, which was introduced earlier this year, 16 individuals and 3 entities have been sanctioned, including a covert unit of the Russian military intelligence GRU Unit 29155, disinformation network Groupe Panafricain pour le Commerce et l’Investissement (GPCI) and African news agency African Initiative.
EU Belarus sanctions
The EU also expanded sanctions against Belarus, imposing asset freezing measures on 26 individuals and 2 entities, including a Belarussian transport and storage company, Vlate Logistik LLC.
Other sanctions
The EU added new designations to its Haiti, Sudanese, and North Korea sanctions regimes.
Chapter 2 - What to expect next?
This sanctions package is expected to be the last sanctions package of the Hungarian Presidency of the Council of the European Union. From January 2025, Poland will take the presidency of the Council. It is expected that Poland will work on the adoption in Q1 2025 of a 16th sanctions package that may contain new measures that could impact EU operators significantly. The adoption of new EU sanctions requires a unanimous decision by all Member States of the European Union.
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