EU adopts additional sanctions in response to situation in Ukraine


On 6 October 2022, the EU adopted additional sanctions in response to Russia’s illegal and unprovoked military aggression against Ukraine. These sanctions build on, and expand, the earlier sanctions.

EU sanctions regulations have direct effect in all Member States of the EU, and, as such, are legally binding on all natural and legal persons in Ireland. Private companies, therefore, have an obligation to ensure that they are in full compliance with these new measures. A natural or legal person who contravenes a provision of an EU sanctions regulation shall be guilty of an offence and liable to prosecution.

This webpage summarises the key trade provisions of the EU sanctions enacted to date. The Department of Enterprise, Trade and Employment has prepared an associated Guidance Notice.

The 8th package of EU sanctions came into effect on 7 October 2022. The major trade-related elements of the package, which are set out in Council Regulation (EU) 2022/1904 of 6 October 2022 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, are as follows:

I Extends the prohibition on the provision of services to Russia to include the provision of 

a) architectural and engineering services, including integrated engineering services, urban planning and landscape architectural services and engineering related scientific and technical consulting services,

b) IT consultancy services, covering the installation of computer hardware and software implementation services, including assistance services to the clients in the installation of computer hardware and computer networks, and all consultancy services involving development and implementation of software, and

c) legal advisory services

II Prohibition on the sale, supply, transfer or export of firearms, their parts and essential components and ammunition.
III Further extends the import ban on coal and other products that either originate in Russia or have been exported from Russia. 

IV Further extends the import ban on iron and steel products that either originate in Russia or have been exported from Russia. 

V Additions to the lists of items which generate significant revenues for Russia, whose import is prohibited, including 
a) wood pulp and paper,
b) certain stones and precious metals used in the jewellery industry,
c) certain machinery and chemical items,
d) cigarettes,
e) plastics and finished chemical products such as cosmetics 

VI Additions to the list of goods which could contribute to the enhancement of Russian industrial capacities, whose export is prohibited. 

VII Additions to the list of goods which could contribute to Russia’s military and technological enhancement, whose export is prohibited. 

VIII Additions to the list of goods used in the aviation sector, whosesale, supply transfer or export is prohibited. 

IX Prohibits the maritime transport, including through ship-to-ship transfers, of certain crude oil and certain petroleum products which originate in Russia, or which have been exported from Russia, to third countries. 

X Introduction of an exemption from the prohibition on the maritime transport by vessel to third countries of crude oil or petroleum products which originate in or are exported from Russia, and on the provision of technical assistance, brokering services or financing or financial assistance related to these products, where they have been purchased at or below a pre-established price cap set by the Price Cap Setting Body of the G7+ Price Cap Coalition. 

XI The ban on Russian-flagged vessels accessing EU ports and locks now also applies to vessels certified by the Russian Maritime Register of Shipping. 

XII A ban on EU nationals to hold any posts on the governing bodies of certain listed state-owned or controlled entities or bodies. 
Additionally, Council Regulation (EU) 2022/263, as amended, which includes provisions restricting certain trading activities, both import and export, has been extended to include the four regions illegally annexed by Russia, the non-government controlled areas of Ukraine in the oblasts of Donetsk, Kherson, Luhansk and Zaporizhzhia. 

NOTE: 1,435 Russian and 230 Belarusian legal persons, entities and bodies, are currently subject to financial sanctions. Therefore, members should carry out appropriate due diligence, including thorough screening of all parties to a transaction, to avoid inadvertently breaching the sanctions.