Sun. May 29th, 2022

28 April 2022

Infographic – EU sanctions in response to Russia’s invasion of Ukraine: See full infographic

Since Russia’s recognition of the non-government-controlled areas of the Donetsk and Luhansk oblasts in Ukraine on 21 February 2022 and the unprovoked and unjustified invasion of Ukraine on 24 February 2022, the EU has imposed a series of new sanctions against Russia.

They add to existing measures imposed on Russia since 2014 following the annexation of Crimea and the non-implementation of the Minsk agreements.

On this page you can find answers to the following questions:

  • what sanctions has the EU adopted so far, who is being sanctioned and what individual sanctions mean in practice?
  • what do the restrictive measures against Russian banks and the National Central Bank of Russia mean in practice?
  • what are the sanctions on aviation, road and maritime transport?
  • how is the EU’s trade with Russia being affected by the EU measures and what kind of import and export restrictions are in force?
  • are EU sanctions compliant with international law and are they coordinated with other partners?
What sanctions has the EU adopted so far?

Since February, the EU has imposed five packages of sanctions against Russia, including targeted restrictive measures (individual sanctions), economic sanctions and diplomatic measures.

The EU has also adopted sanctions against Belarus in response to its involvement in the invasion of Ukraine.

The aim of the economic sanctions is to impose severe consequences on Russia for its actions and to effectively thwart Russian abilities to continue the aggression.

The individual sanctions target people responsible for supporting, financing or implementing actions which undermine the territorial integrity, sovereignty and independence of Ukraine or who benefit from these actions.

Who is being sanctioned?

In total, also taking into account earlier individual sanctions imposed after the annexation of Crimea in 2014, the EU has sanctioned 80 entities and 1093 individuals. The list includes:

  • Russia’s President, Vladimir Putin
  • Russia’s Minister for Foreign Affairs, Sergey Lavrov
  • oligarchs linked to the Kremlin, such as Roman Abramovich
  • 351 members of the Russian State Duma (the lower house of parliament) who voted in favour of the recognition of Donetsk and Luhansk on 15 February 2022
  • members of the National Security Council
  • high-ranking officials and military personnel
  • prominent businesspeople (i.e. people active in the Russian steel industry and others who provide financial services, military products and technology to the Russian state)
  • propagandists and disinformation actors
  • selected family members of some of the abovementioned individuals
What do sanctions on individuals mean in practice?

Sanctions on individuals consist of travel bans and asset freezes. Travel bans prevent listed individuals from entering or transiting through EU territory, by either land, air or sea.

Asset freezes mean that all accounts belonging to the listed persons and entities in EU banks are frozen. It is also prohibited to make any funds or assets directly or indirectly available to them.

This ensures that their money can no longer be used to support the Russian regime nor can they try to find a safe haven in the EU.

How is the EU’s trade with Russia being sanctioned?

As part of the economic sanctions, the EU has imposed a number of import and export restrictions on Russia. This means that European entities cannot sell certain products to Russia (export restrictions) and that Russian entities are not allowed to sell certain products to the EU (import restrictions).

The list of banned products is designed to maximise the negative impact of the sanctions for the Russian economy while limiting the consequences for EU businesses and citizens. The export and import restrictions exclude products primarily intended for consumption and products related to health, pharma, food and agriculture, in order not to harm the Russian population.

The bans are implemented by the EU’s customs authorities.

Moreover, the EU, in collaboration with other like-minded partners, has adopted a statement reserving the right to stop treating Russia as a most-favoured-nation within the WTO framework. The EU has decided to act on this not through an increase in import tariffs, but through a set of restrictive measures that include bans on the import or export of certain goods. The EU and its partners have also suspended any work related to the accession of Belarus to the WTO.

What goods cannot be exported to Russia from the EU?

The list of sanctioned products includes among others:

  • cutting-edge technology (e.g. quantum computers and advanced semiconductors, high-end electronics and software)
  • certain types of machinery and transportation equipment
  • specific goods and technology needed for oil refining
  • energy industry equipment, technology and services
  • aviation and space industry goods and technology (e.g. aircraft, spare parts or any kind of equipment for planes and helicopters, jet fuel)
  • maritime navigation goods and radio communication technology
  • a number of dual-use goods (goods that could be used for both civil and military purposes), such as drones and software for drones or encryption devices
  • luxury goods (e.g. luxury cars, watches, jewellery)
What goods cannot be imported from Russia to the EU?

The list of sanctioned products includes among others:

  • coal and other solid fossil fuels (as there is a wind-down period for existing contracts, this sanction will apply as from August 2022)
  • steel and iron
  • wood, cement and certain fertilisers
  • seafood and liquor (e.g. caviar, vodka)
What do sanctions in the aviation sector mean?

In February 2022, the EU refused access to EU airports for Russian carriers of all kinds and banned them from overflying EU airspace. This means that airplanes registered in Russia or elsewhere and leased or rented to a Russian citizen or entity cannot land at any EU airports and cannot fly over EU countries. Private aircraft, e.g. private business jets, are included in the ban.

In addition, the EU banned the export to Russia of goods and technology in the aviation and space industry.

Insurance services, maintenance services and technical assistance related to these goods and technology are also prohibited. The United States, Canada and the United Kingdom imposed similar restrictions.

This means that Russian airlines cannot buy any aircraft, spare parts or equipment for their fleet and cannot perform the necessary repairs or technical inspections. As three-quarters of Russia’s current commercial air fleet were produced in the EU, the US or Canada, over time the ban is likely to result in the grounding of a significant proportion of the Russian civil aviation fleet, even for domestic flights.

What are the sanctions on road transport?

The EU has prohibited Russian and Belarusian road transport operators from entering the EU, including for goods in transit.

This sanction aims to restrict Russian industry’s capacity to acquire key goods and to disrupt road trade both to and from Russia. However, EU countries can grant derogations for:

  • the transport of energy
  • the transport of pharmaceutical, medical, agricultural and food products
  • humanitarian aid purposes
  • transport related to the functioning of diplomatic and consular representations of the EU and its countries in Russia, or of international organisations in Russia which enjoy immunities in accordance with international law
  • the transfer or export to Russia of cultural goods on loan in the context of formal cultural cooperation with Russia

The ban does not affect mail services and goods in transit between Kaliningrad Oblast and Russia.

What are the sanctions on maritime transport?

The EU has closed its ports to Russia’s entire merchant fleet of over 2 800 vessels. However, the measure does not affect vessels carrying:

  • energy
  • pharmaceutical, medical, agricultural and food products
  • humanitarian aid
  • nuclear fuel and other goods necessary for the functioning of civil nuclear capabilities
  • coal (until 10 August 2022, after which imports of coal into the EU will be banned)

The measure also does not affect vessels in need of assistance seeking a place of refuge, or vessels making an emergency port call for reasons of maritime safety or saving life at sea.

The ban will also apply to vessels that try to evade the sanctions by changing their Russian flag or registration to that of another state. Port authorities can identify an attempt to reflag or change registration by checking a vessel’s IMO number (the unique identification number assigned on behalf of the International Maritime Organization).

What does the SWIFT ban mean for Russian and Belarusian banks?

The ban prevents seven Russian and three Belarusian banks from making or receiving international payments using SWIFT.

SWIFT is a messaging service that substantially facilitates information exchange between banks and other financial institutions. SWIFT connects more than 11 000 entities worldwide.

As a result, these banks can neither get foreign currency (as a transfer of foreign currencies between two banks is generally processed as a transfer abroad involving a foreign intermediary bank) nor transfer assets abroad. This has negative consequences for the Russian and Belarusian economies.

Technically, banks could carry out international transactions without SWIFT, but it is expensive, complex and requires mutual trust between financial institutions. It brings payments back to the times when telephone and fax were used to confirm each transaction.

What do the sanctions against the National Central Bank of Russia mean in practice?

The European Union has prohibited all transactions with the National Central Bank of Russia related to the management of the Russian Central Bank’s reserves and assets. As a result of the central bank asset freeze, the central bank can no longer access the assets it has stored in central banks and private institutions in the EU.

In February 2022, Russia’s international reserves accounted for $643 billion (€579 billion). Among other purposes, having reserves in foreign currencies helps keep the exchange rate of a country’s own currency stable.

Due to the ban on transactions from the EU and other countries, it is estimated that more than half of Russian reserves are frozen. The ban was also imposed by other countries (such as the US, Canada and the UK) which also store a share of Russia’s foreign reserves.

Consequently, Russia cannot use this cushion of foreign assets to provide funds to its banks and thus limit the effects of other sanctions. Even the gold reserves stored in Russia now appear to be more difficult to sell due to international sanctions affecting Russian entities.

The EU has also prohibited the sale, supply, transfer and export of euro-denominated banknotes to Russia. The aim is to limit access to cash in euro by the Russian government, its Central Bank and natural or legal persons in Russia with a view to preventing the circumvention of sanctions.

Similar sanctions apply to Belarus.

Why has the EU suspended the broadcasting of Sputnik and Russia Today?

Russia uses both Sputnik and Russia Today (state-owned outlets) to intentionally spread propaganda and conduct disinformation campaigns, including about its military aggression against Ukraine.

Sputnik and Russia Today are essential and instrumental in bringing forward and supporting the military aggression against Ukraine, and for the destabilisation of its neighbouring countries.

The Russian Federation has engaged in a systematic, international campaign of disinformation, information manipulation and distortion of facts in order to enhance its strategy of destabilising its neighbouring countries, the EU and its member states.

The restrictions, in place since 2 March 2022, apply to Sputnik and Russia Today (including their subsidiaries, such as RT English, RT UK, RT Germany, RT France and RT Spanish) and cover all means of transmission and distribution in or directed at the EU member states, including cable, satellite, Internet Protocol TV, platforms, websites and apps.

Is the EU coordinating the sanctions with other partners?

Sanctions are more effective if a broad range of international partners are involved. The EU has worked closely over the last few weeks with like-minded partners such as the United States in order to coordinate sanctions.

The EU is working with the World Bank Group, the European Bank for Reconstruction and Development (EBRD), the Organisation for Economic Co-operation and Development (OECD) and other international partners to prevent Russia from obtaining financing from such institutions.

To coordinate this international effort, the newly formed Russian Elites, Proxies, and Oligarchs (REPO) Task Force allows the EU to cooperate with the G7 countries – Canada, France, Germany, Italy, Japan, the United Kingdom and the United States – as well as with Australia, to ensure sanctions are implemented.

Although the EU works closely with many partners, each of these non-EU countries decides unilaterally which sanctions it will impose.

Do EU sanctions fall under international law?

Yes. All EU sanctions are fully compliant with obligations under international law, whilst respecting human rights and fundamental freedoms.

Once political agreement is reached among EU member states, the necessary legal acts are prepared by the European External Action Service and/or the European Commission and submitted to the Council for adoption.

Council regulations and decisions, as legal acts of general application, are binding on any person or entity under EU jurisdiction. This means any person or entity within the EU, any EU national in any location, and all companies and organisations incorporated under the law of an EU member state.

See also